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It’s been 4 years since President Obama signed the Affordable Care Act authorizing menu labels to go national.

In 2011, the FDA proposed rules for public comment.  It proposed final rules in 2013:

• Rules for restaurant menu boards
• Rules for vending machines

But the FDA has never released the final rules.

How come?

The rumors I’m hearing say they are being held up by the White House Office of Management and Budget.

I first wrote about the delay in April 2013.

I complained about the delay again four months ago, when rumors suggested that it was due to pressures from owners of pizza chains and movie theaters.

I quoted Politico Pro Agriculture on the White House-induced delay:

It was three months ago today that the White House first received FDA’s final rules for calorie labels on menus and vending machines, and by the Office of Management and budget’s own rules, that means time is up. Interagency review at OMB is supposed to take no more than 90 days before the final release of a measure, though that timeframe is often extended with little explanation on more controversial initiatives. While OMB is always mum on its schedule for rule reviews and releases, the end of the standard review period is sometimes a hint that something will be coming, if not today — the day before a long weekend — then soon. In the meantime, brush up on the issue here: http://politico.pro/1mKNcFr and here: http://politico.pro/1lzZLDe.

Come on White House OMB: the election is over.  Let the FDA release the rules, please.

This is about public education, which is supposed to be bipartisan.

Remember menu labels?  We’ve had them in New York City since 2008.

In 2010, President signed national menu labeling into law as part of the Affordable Care Act.  The FDA proposed rules for labels in 2011, collected comments on the proposed rules, missed the July 3, 2014 deadline for issuing them, and by all reports sent them to the White House Office of Management and Budget last April.

• Food Labeling; Nutrition Labeling of Standard Menu Items in Restaurants and Similar Retail Food Establishments; Proposed Rule
• Food Labeling; Calorie Labeling of Articles of Food in Vending Machines; Proposed Rule

What is the holdup?  Lobbying of course.

• The delay on releasing the final rules is widely reported to be due to lobbying efforts by industry groups.  Known to have visited the White House and FDA officials are, among others, the Food Marketing Institute, Publix Super Market, Schnuck Markets, Kroger, Dominos Pizza, the Pizza Hut Franchise Association and Hungry Howies.
• The Food Marketing Institute (FMI), the National Grocers Association (NGA) and Food Industry Association Executives (FIAE) held a lobbying “fly-in” to prevent FDA’s final menu labeling rule for calorie disclosures being extended to grocery stores.
• A bill backed by the supermarket industry is the Common Sense Nutrition Disclosure Act (H.R. 1249/S. 1756) which would require menu labeling only for establishments where the majority of business is derived from restaurant-type food.

As for whether menu labels do any good:

• A CDC study reports that nearly all adults say they notice menu calorie labels, but only 57% say they use them.
• Research on the effectiveness of menu labeling has yielded mixed results and more research is needed, says a review published by the Robert Wood Johnson Foundation.
• One recent study says menu labeling has little influence on calories ordered regardless of how overweight people are.
• Menu labeling raises ethical issues related to population health and social equity, says another study.

At the moment, studies of the effects of menu labeling are restricted to laboratory models or situations in New York and other cities that passed such laws within the last few years.

More definitive research must wait for the final FDA rules and their application.

How about releasing the rules soon?  They’ve been dragging on way too long.

 

 

In June I wrote about the FDA’s advice to pregnant women to avoid eating fish high in methylmercury.  The advisory said to avoid the four fish highest in methylmercury:  shark, swordfish, king mackerel, and tilefish.

I was surprised that the advisory didn’t warn about the high mercury levels in albacore tuna, and I was skeptical about the FDA’s  insistence that pregnant women must eat fish.

Now Consumer Reports advises pregnant women not to eat tuna at all.

Consumer Reports:

• Asks  FDA Deputy Commissioner Mike Taylor to fix the charts it released with its advisory to make it clear that tuna is a high-mercury fish
• Issues copies of the charts showing amounts of methymercury in various kinds of fish.
• Publishes an article on the problems with mercury in fish.
• Gives the methods used as a basis for the article.

So what’s going on here?

In my book, What to Eat, I included a chapter on this very topic: “The Methylmercury Dilemma.”  Here’s a quote:

Albacore tuna clearly belonged on the list of fish to avoid, but advice to restrict its consumption would surely affect the livelihoods of people who fish for, can, and sell tuna.   Because hardly anyone knows the difference between one kind of tuna and another, fish companies worried that consumers would interpret advice to avoid albacore tuna as advice to avoid all tuna.  Industry lobbyists urged the FDA to keep albacore tuna off the methylmercury advisory.   Somehow, albacore tuna got left off.

That was in 2006.   Consumer Reports tells us that pretty much all tuna is too high in methylmercury to be consumed by pregnant women.  So this comment still seems relevant, no?

Evidence: Here’s the response from the National Fisheries Institute:  “Consumer Reports has long history of intentionally mischaracterizing tuna.”

Food Navigator—USA’s Elaine Watson just put together a special edition on the revamping of the Nutrition Facts label.  Her title: Radical overhaul or a missed opportunity?

To understand what’s happening with food labels, you can start with the FDA’s home page on its proposed revisions.  The comment period has ended.  You can read the comments that have been filed on the Nutrition and Supplement Facts panels, and those filed on the proposed changes to the standards for serving sizes.  These are fun to read; opinions, to say the least, vary.

But back to Food Navigator, which collects in various pieces on the topic in one place.  The “Radical overhaul” piece contains a summary of the major provisions.  Others in the series are also useful (I’m quoted in some of them):

Does vitamin D belong on the Nutrition Facts panel?

FDA proposals to list “added sugars” on the Nutrition Facts panel have already generated heated debate, so it’s perhaps unsurprising that its plan to include vitamin D is proving equally controversial…

Should ‘added sugars’ be listed on the Nutrition Facts panel?

A row is brewing over the merits of including ‘added sugars’ on the Nutrition Facts panel, with critics arguing that our bodies don’t distinguish between ‘naturally occurring’ and ‘added’ sugar – and neither should food labels – and supporters saying it will help consumers identify foods with more empty calories.

 Nutrition Facts overhaul is a missed opportunity for long chain omega-3s EPA and DHA, says GOED

The FDA’s overhaul of the Nutrition Facts panel misses a public health opportunity by prohibiting firms from even highlighting long chain omega-3 fatty acids EPA and DHA on the panel, says GOED.

What are the biggest contributors of added sugars to the US diet?

Check out this analysis of NHANES data to see where our added sugars are coming from plus read new comments about the ‘added sugars’ labeling proposal from Ocean Spray cranberries and others.

Former FDA commissioner: Nutrition Facts overhaul doesn’t go far enough

FDA proposals to overhaul the Nutrition Facts panel on food labels don’t got far enough, says former FDA commissioner David Kessler, M.D.

Behavioral scientists: Changing serving sizes on Nutrition Facts label could have unintended consequences

FDA proposals to change the way serving sizes are calculated to better reflect real-life eating behavior could encourage some people to eat even more unless the wording is changed, says one expert group.

Until phosphorus gets on the USDA’s radar, labeling policy won’t change: NKF

While phosphorus is an essential nutrient found naturally in some foods such as egg yolk and milk, it is increasingly added to packaged foods via a raft of phosphorus additives, and some experts believe it should be listed on the Nutrition Facts panel.

Canada’s proposed Nutrition Label changes emphasize calories, sugar

Health Canada is proposing changes to nutrition labels that would make them easier for consumers to read.

RD: There’s a health continuum for every food; what pillars do you want to stand on?

Rachel Cheatham, RD, founder of nutrition strategy consultancy FoodScape Group, talks food labeling at the IFT show.

Is your product ready for nutrition label changes?

“A 16-ounce drink and a two-ounce bag of potato chips are a single serving. If it’s bigger than that, from 200 to 400%, then you need to declare two columns of information—one for the serving size and one for the whole container.”

Proposed nutrition labels more effective than current labels: survey

Consumers find proposed labels easier to read in less time.

How much do consumers use (and understand) nutrition labels?

New research from the NPD Group is questioning how many US consumers even routinely check nutrition labels anymore.

 FDA’s proposed nutrition label changes emphasize calories, serving sizes

If approved, the new labels would place a bigger emphasis on total calories and update serving sizes, while also drawing attention to added sugars and nutrients such as Vitamin D and potassium.

CRN, NPA submit comments on FDA’s proposed changes to food, supplement labels

Both the Council for Responsible Nutrition and the Natural Products Association have submitted a comments on FDA’s proposed revisions for food and dietary supplement labels.

The FDA’s next step is to deal with the comments and issue final rules.  By when?

Eventually.  Stay tuned.

The FDA is taking comments on its proposals to revamp the food label through August 1, 2014 (instructions are at bottom of post).

I’ve already filed comments on Added Sugars and on whether Vitamin D should be added to food labels.

And I just filed further comments on the FDA’s proposals for the Nutrition and Supplement Facts Labels.  If you would like to read what I said, click here.

I’ve also filed comments on the FDA’s Serving Size proposals.

These proposals are highly technical and tough to slog through, so I tried to deal with the big picture.

July 27, 2014

TO:                  FDA

FROM:           Marion Nestle, Professor of Nutrition, Food Studies and Public Health, New York University

RE:                  Comments: Serving size proposals, Docket No. FDA-2004-N-0258

In addressing the question of how to change serving size designations on food labels, FDA is faced with an impossible dilemma .  Serving sizes, which are supposed to be based on amounts typically consumed from packaged products, are invariably perceived as recommendations for dietary intake.

To comment on each of the bold-face, italicized points:

• Typically consumed:  This information derives from dietary intake surveys which invariably underestimate actual intake, often by 30% to 40%.

• Packaged foods: Food labels only appear on packaged foods.  RACC amounts on packaged foods are often much lower than amounts served in restaurants or fast-food places (pizza is an obvious example).  It is unclear whether amounts reported as consumed are from packages (with Nutrition Facts labels) or are from restaurants or fast-food places where portion sizes can be much higher than those for foods in packages.

• Recommendation:  Substantial anecdotal information suggests that people view labeled serving sizes as what they should be eating.  They view the serving sizes as meaningless compared to the portion sizes of foods they are accustomed to eating.

What is well established is that overall calorie intake has increased since RACCs were established in 1993 and marketplace portion sizes have also increased.

Therefore, any increase in RACC runs the risk of being interpreted as a validation of current portion sizes and as a recommendation to eat more.

On the other hand, larger portions have more calories.  These must appear on the label.

To address this dilemma, FDA should:

• Make dual-column labeling mandatory for all food and beverage packages likely to be consumed in one sitting.
• Require total calories in the package to be displayed on the front of the package.
• Include a footnote explaining that the serving size is not meant as a recommendation

INSTRUCTIONS FOR FILING COMMENTS

The FDA provides:

• All necessary information in one place.
• A short guide and checklist

File comments here

• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

The FDA is taking comments on label proposals until August 1 (see info at end of post).  Here’s mine on voluntary vitamin D labeling.

July 17, 2014

TO:  FDA

FROM:  Marion Nestle, Professor, New York University

RE:  Proposed revision to Nutrition Facts Panel: VITAMIN D

This is to argue against permitting food companies to voluntarily label added “Vitamin” D on the Nutrition Facts panel.  Doing so will not promote—and may possibly harm–public health.

Rationale

• “Vitamin” D is not a vitamin; it is a hormone synthesized by the action of sunlight on skin.  For this reason alone, it does not belong on the food label.
• Vitamin D fortification must be understood as a form of hormone replacement therapy.   As such, it raises questions about efficacy, dose, and side effects that should be asked about all such therapies.
• Fortification and supplementation provide hormone Vitamin D by the oral route.  This is not physiological.  Active vitamin D is synthesized in the body through a series of reactions that begin with the action of sunlight on skin.  Sunlight on skin produces ample Vitamin D, is regulated to promote synthesis as needed and avoid toxicity, and may lead to synthesis of other useful biological components; the unphysiologic oral route does not produce the same benefits.[i]
• As a hormone, Vitamin D is found naturally in very few foods (e.g., fish); in them, it is present in small amounts.  It is present in most foods as a result of fortification.
• Permitting Vitamin D to be listed on food labels will encourage fortification, undoubtedly of foods that would not otherwise necessarily be recommended.  To cite just one example: Yum Bunny Caramel Milk Spread fortified with vitamin D at 10% of the DV.  This product is half sugars by weight, marketed as “a good source of calcium and vitamin D,” and clearly aimed at children. See: http://www.yumbunny.com/about-us.   Whether such products should be considered “good sources” also deserves scrutiny.
• The U.S. Preventive Services Task Force concludes that evidence is insufficient to determine how Vitamin D supplementation (and, therefore, fortification) affects fracture incidence.[ii]^,[iii],[iv] 
• Data from the Women’s Health Initiative also are consistent with largely inconclusive findings about hormone Vitamin D supplements and bone health.[v]
• The Institute of Medicine (IOM) does not consider deficiency of Vitamin D to be a serious problem in the United States, except among certain population groups.  Instead, because of widespread fortification and supplementation, it is concerned about the possibility of adverse consequences from overconsumption through supplementation or fortification.[vi]
• Many scientific debates about hormone Vitamin D are as yet unresolved.[vii]^,[viii]  
• The lack of compelling research has permitted Vitamin D to become “trendy.”  It is advertised on boxes of fortified cereals, has its own pro-supplement advocacy group, and generates millions in annual supplement sales.[ix]

In the absence of stronger evidence for benefit from fortification, and some evidence for possible adverse consequences, the FDA should not contribute to further commercialization of this misnamed hormone by permitting it to be listed on food labels.

References

[i] Wacker M, Holick MF.  Sunlight and Vitamin D: A global perspective for health. Dermato-Endocrinology 2013;5(1):51–108.

[ii] Cranney A, Horsley T, O’Donnell S, Weiler H, Puil L, Ooi D, et al.  Effectiveness and safety of vitamin D in relation to bone health. Evidence Report/Technology Assessment No. 158. Rockville, MD: Agency for Healthcare Research and Quality. 2007.  http://www.ncbi.nlm.nih.gov/books/NBK38410. Accessed February 5, 2013.

[iii] Chung M, Balk EM, Brendel M, Ip S, Lau J, Lee J, et al  Vitamin D and calcium: a systematic review of health outcomes. Evidence Report/Technology Assessment No. 183. Rockville, MD: Agency for Healthcare Research and Quality. 2009.  http://www.ncbi.nlm.nih.gov/books/NBK32603/. Accessed February 5, 2013.

[iv] Chung M, Lee J, Terasawa T, Lau J, Trikalinos T. Vitamin D with or without calcium supplementation for prevention of cancer and fractures: an updated meta-analysis for the U.S. Preventive Services Task Force. Ann Intern Med. 2011;155(12):827-38.

[v] Prentice RL, Pettinger MB, Jackson RD, Wactawski-Wende J, LaCroix AZ, Anderson GL, et al.  Health risks and benefits from calcium and vitamin D supplementation: Women’s Health Initiative clinical trial and cohort study.  Osteoporosis Int.  2013;24(2):567-580.

[vi] Institute of Medicine.  Dietary Reference Intakes: Calcium, Vitamin D.  Washington, DC: National Academies Press, 2011.

[vii] Rosen, Clifford J,  Abrams, Steven A,  Aloia John F. et al.  IOM Committee members respond to endocrine society vitamin D guideline. J Clin Endocrinol Metab. 2012;97:1146-1152.

[viii] Holick, Michael F,  Brinkley Neil C, Heike, A et al  Guidelines for preventing and treating vitamin D deficiency and insufficiency revisited.  J Clin Endocrinol Metab. 2012;97:1153-1158.

[ix] Much growth in vitamin sales driven by vitamin D.  Nutr Business J. 2009;14(6/7):5.

Here’s how to file comments:

The proposed revisions are to:

• Nutrition and Supplement Facts Labels
• Serving Sizes 

The FDA makes it very easy to file comments. It provides:

• All necessary information in one place.
• A short guide and checklist

File comments here

• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

The FDA is taking comments on its proposals to revamp the food label until August 1, 2014.

It has two sets of proposed changes:

• Nutrition and Supplement Facts Labels
• Serving Sizes

Here is the first of my comments on several food label items.  Feel free to copy, edit, or file your own (see directions below).

July 16, 2014

TO:  FDA

FROM:  Marion Nestle, Professor, New York University

RE:  Nutrition Facts panel: ADDED SUGARS

1.  Retain the line for Sugars but call it Total Sugars

2.  Add a line for Added Sugars

Rationale:

• Excessive intake of dietary sugars is well established to raise the risk of obesity and type-2 diabetes.[i]
• Americans on average twice as much as is generally recommended.[ii]
• The amount typically consumed comes close to the upper limit recommended by the Institute of Medicine on the basis of increased risk of nutrient deficiencies.[iii]
• Sugars intrinsic to foods are accompanied by nutrients; added sugars are not.
• Although there is no biochemical difference between intrinsic and added sugars, food and beverage companies know exactly how much sugar they add as part of the recipes for their products.
• Listing the amount of added sugars on food labels would inform consumers about how much sugars are added to the foods they buy.
• Randomized, controlled clinical trials to test the hypothesis that added sugars increase disease risk would violate ethical standards and, therefore, are impossible to conduct.

3.  Establish a Daily Reference Value for Added Sugars of 10% of total calories

Rationale:

• Since the 1977 Dietary Goals, health officials have consistently recommended an upper limit of 10 percent of calories from added sugars.[iv]
• The 1992 USDA Food Guide Pyramid suggested an upper limit of 6, 12, and 18 teaspoons of sugars, respectively, for daily diets of 1,600, 2,200, and 2,800 calories, respectively.  This works out to 7, 10, and 13 percent of calorie intake, respectively, for an average of 10 percent.[v]
• By 1992, health officials in several European countries had recommended much the same.[vi]
• The Institute of Medicine’s 2002 upper safety limit of 25% of calories was based on risk for nutrient deficiencies, not obesity and chronic disease.[vii]
• In 2009, the American Heart Association recommended that women consume no more than 100 calories per day from added sugars (25 grams), and men no more than 150 calories per day (38 grams).  These come to 5 percent and 7.5 percent, respectively, of a 2000-calorie daily diet.[viii]
• The 2010 Dietary Guidelines for Americans state that no more than 5 to 15 percent of calories should come from a combination of solid fats and added sugars.  This implies that added sugars should be less than 10% of calories.^[ix]
• Dr. Robert Lustig says that a “dose” of added sugars up to 50 grams a day poses little risk for metabolic or chronic disease.  This amounts to 200 sugar calories and 10% of a 2,000-calorie daily diet (he says twice that much, the amount commonly consumed by Americans, is toxic.[x]
• The World Health Organization in 2014 said that added sugars should make up less than 10 percent of total calories per day, and less than 5 percent would be even better,[xi] based on two research reviews, one on sugars and obesity[xii]  and one on sugars and tooth decay.[xiii]
• Added sugars as 10% of calories represents about half the amounts currently consumed and comes close to consensus.

References

[i] Te Morenga L, Mallard S, Mann J. Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and cohttp://steinhardt.nyu.edu/nutrition/hort studies. BMJ 2012;345:e7492.  doi: 10.1136/bmj.e7492.

[ii] USDA.  Loss-adjusted food availability documentation.  March 11, 2014.  http://www.ers.usda.gov/data-products/food-availability-(per-capita)-data-system/loss-adjusted-food-availability-documentation.aspx#.UzlzcfldU6w.   USDA.  Food availability documentation: added sugar and sweeteners.  http://www.ers.usda.gov/data-products/food-availability-(per-capita)-data-system/food-availability-documentation.aspx#sugar.   The tables used to construct figure 3D are at: Refined Sugar, Corn Syrup, Other Sweeteners.

[iii] Institute of Medicine (IOM) of the National Academies. “Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol, Protein, and Amino Acids (Macronutrients), Chapter 6: Dietary Carbohydrates: Sugars and Starches”, Washington, DC: National Academies Press; 2002.

[iv] U.S. Senate Committee on Nutrition and Human Needs.  Dietary Goals for the United States, December 1977.

[v] USDA.  Food Guide Pyramid, 1992.

[vi] Cannon G:  Food and Health: The Experts Agree.  London:  Consumers’ Association, 1992.

[vii] USDA.  Is intake of added sugars associated with diet quality?  Nutrition Insights, Insight 21, October 2000.

[viii] Johnson RK, Appel LJ, Brands M, et al.  Dietary sugars intake and cardiovascular health: a scientific statement from the American Heart Association.  Circulation. 2009;120(11):1011-1120.  doi: 10.1161/CirculationAHA.109.192627.

[ix] USDA and USDHHS.  Dietary guidelines for Americans, 2010.  http://www.cnpp.usda.gov/dgas2010-policydocument.htm.

[x] Lustig RH.  Fat Chance: Beating the Odds Against Sugar, Processed Food, Obesity, and Disease.  Hudson Street Press, 2012.

[xi] WHO.  Draft guideline: Sugars intake for adults and children, March 2014. http://www.who.int/nutrition/sugars_public_consultation/en/.

[xii] Te Morenga L, Mallard S, Mann J. Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and cohort studies. BMJ 2012;345:e7492 doi: 10.1136/bmj.e7492.

[xiii] Moynihan PJ, Kelly SAM.  Effect on Caries of Restricting Sugars Intake. Systematic Review to Inform WHO Guidelines.  JDR 2014;93:8-18.  doi:10.1177/0022034513508954.

 

The FDA makes it easy to file comments. It provides:

• All necessary information in one place.
• A short guide and checklist
• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

When the FDA advisory came out a week or so ago, I started getting questions about whether it meant that women must eat fish during pregnancy and, if so, how much.

As I said in my previous post on the topic, if you like fish, of course eat it, otherwise I can’t think of any compelling reason why anyone has to eat fish.

I view the data on the dilemma caused by omega-3 fatty acids in fish (good) versus the content of methylmercury (bad) as still rather uncertain.  Dr. Malden Nesheim and I discussed this point in an editorial we wrote for the American Journal of Clinical Nutrition [reference 1 below].

Here’s what the FDA advisory says:

Eat 8 to 12 ounces of a variety of fish each week from choices that are lower in mercury. The nutritional value of fish is important during growth and development before birth, in early infancy for breastfed infants, and in childhood… Fish contains important nutrients for developing fetuses, infants who are breastfed, and young children. Fish provides health benefits for the general public. Many people do not currently eat the recommended amount of fish.

This is a prescriptive statement telling pregnant women that they should eat fish.

I would argue that the data on which FDA based this prescription are limited, especially because the results of its scientific assessment are based mostly on theoretical models rather than empirical studies.

Here’s what makes me think some skepticism is warranted:

1. The effects of even low-level methylmercury exposure may be greater than discussed in the assessment [see reference 2], as the latest analysis from the Environmental Working Group explains.
2. The increase in young children’s IQ associated with fish-eating during pregnancy is low—-0.7 to a maximum of 3 IQ points.

As the FDA’s assessment report says:

On a population basis, average neurodevelopment in this country is estimated to benefit by nearly 0.7 of an IQ point (95% C.I. of 0.39 – 1.37 IQ points) from maternal consumption of commercial fish. For comparison purposes, the average population-level benefit for early age verbal development is equivalent in size to 1.02 of an IQ point (95% C.I. of 0.44 – 2.01 IQ size equivalence). For a sensitive endpoint as estimated by tests of later age verbal development, the average population-level benefit from fish consumption is estimated to be 1.41 verbal IQ points (0.91, 2.00). The assessment also estimates that a mean maximum improvement of about three IQ points is possible from fish consumption, depending on the types and amounts of fish consumed.

How significant is this?  And does the small benefit in childhood persist into adolescence or adulthood?

3. The economic question.  Fish are expensive.
4. The ecological questions.  Advice to increase fish consumption comes up against environmental realities—-overfishing, fish farming—-that make the recommendation impossibly unsustainable [reference 3].

• The levels of long-chain omega-3s in farmed fish depend on feeding them wild fish, an ecological problem on its own.
• Guidance about fish can’t be just nutritional; it has to take the economic and ecological impact of fish choices into consideration [reference 4].
• Current per capita fish consumption is about half the FDA recommended level, and half of that is shrimp.  Fortunately, shrimp don’t have much mercury (although the ones from Asia may have other contaminants), but they also don’t have much omega-3).

All of this suggests grounds for skepticism.  I think a better recommendation would leave more wiggle room to account for uncertainties.  Here’s how I would edit the FDA’s statement:

Pregnant women may eat up to 8 to 12 ounces of a variety of fish each week from choices that are lower in mercury.  Fish are useful sources of nutrients that may have value for growth and development before birth, in early infancy for breastfed infants, and in childhood, and may provide health benefits for the general public.  Other food sources also provide such benefits.

References

[1] Nesheim MC, Nestle M. Advice for fish consumption: challenging dilemmas. American Journal of Clinical Nutrition. 2014;99:973-974.

[2] Karagas MR, Choi AL, Oken E, Horvat M, Schoeny R, Kamai E, Cowell W, Grandjean P, Korrick S. Evidence on the human health effects of low-level methymercury  exposure. Environ Health Perspect. 2012; 120:799-806.

[3] Jenkins D, Sievenpiper JL, Pauli D, Sumaila UR, Kendall CWC  Are dietary recommendations for use of fish oils sustainable? Canadian Medical Association Journal 2009;180: 633-637.

[4] Oken E, Choi AL Karagas MR, Marien K, Rheinberger CM, Schoeny R, Sunderland E, Korrick S  Which fish should I eat? Perspectives influencing fish consumption choices. Environmental Health Perspectives 2012;120:790-798.