Technical Information on Development of FDA/EPA Advice about Eating Fish for Those Who Might Become or Are Pregnant or Breastfeeding and Children Ages 1-11 Years

Back to FDA/EPA Advice about Eating Fish Main Page

June 7, 2024

The National Academies of Sciences, Engineering, and Medicine (NASEM) published the final version of the FDA co-sponsored report, The Role of Seafood in Child Growth and Development. The FDA commissioned the study to help provide the agency with the most up-to-date information on seafood and child development.

Among the report’s conclusions, it was determined that there is not enough evidence to suggest a need to revise the amounts of seafood recommended in the Dietary Guidelines for Americans (DGA), and that there is not enough evidence to assess the impact of exposure to contaminants from seafood – other than mercury. However, the report reconfirmed that seafood consumption among maternal and child populations remains low and recommended further development of strategies to support increasing consumption of seafood by children and those who might become or are pregnant or breastfeeding. The report also acknowledged that intake by certain groups —such as Asian and Native Americans and subsistence fishers and their families – is substantively higher.

The report recommends that the FDA routinely monitor the evidence as well as methodologies for integrating and assessing both risks and benefits from seafood on child developmental outcomes, and conduct such analyses to support agency regulations, policies, and programs. The findings highlight many areas for recommended research to fill knowledge gaps around the impact of exposures through seafood consumption on health.

The agency is considering the findings in the NASEM report, along with other data and information, to inform the joint FDA and EPA Advice About Eating Fish and the Closer to Zero Initiative. Closer to Zero is our strategic, long-term, iterative approach to reducing childhood dietary exposure to mercury and other environmental contaminants from foods, while maintaining access to nutritious foods. The FDA is also continuing robust collaborations with federal partners, including sampling and analysis of foods and expanding consumer education work through consumer studies and educational strategies and tools.

March 21, 2024

The National Academies of Sciences, Engineering, and Medicine released a pre-publication version of the FDA-sponsored report, The Role of Seafood in Child Growth and Development. The FDA and other co-sponsors are reviewing the report’s findings and look forward to its final release in May 2024.

The National Academies Committee on The Role of Seafood in Child Growth and Development will provide an overview of their conclusions and recommendations in the pre-publication report in a public webinar.

Date: Tuesday, March 26, 2024
Time: 2 - 3 pm EDT
Location: Event Information and Registration

October 2022

FDA and Federal Partners Launch Study on the Role of Seafood Consumption in Child Growth and Development

Learn more about the National Academies of Sciences, Engineering, and Medicine study that is designed to provide the most up-to-date understanding of the science of seafood consumption and child growth and development that supports the goals of our Closer to Zero Action Plan. It will also help inform whether updates are needed for the current Advice about Eating Fish for children and those who might become or are pregnant or breastfeeding.

October 2021

FDA and EPA have updated their Advice about Eating Fish to incorporate the Dietary Guidelines for Americans, 2020-2025, which includes new dietary recommendations for children under age 2 years and additional guidance for those who are pregnant or breastfeeding.

As part of the Closer to Zero Action Plan, we will continue to evaluate the science and identify actions to reduce exposure to toxic elements like methylmercury while balancing the nutritional benefits of fish as part of a healthy diet.

This web page contains detailed information on the underlying calculations for the fish advice for those who may become pregnant (about 16-49 years old), are pregnant or breastfeeding, and parents and caregivers of children. It contains the following information:

1. How the chart for FDA’s and EPA’s fish advice was derived.
2. Table of fish species that contains data used in separating the fish into categories, such as mercury concentrations and the number of weekly servings.
3. Recommended portion sizes for children based on age.

How FDA and EPA derived the categories in the fish chart

The agencies decided which category each fish or shellfish species (collectively referred to as “fish”) belonged to by calculating the highest average amount of mercury that could be in a fish type when eaten one, two, and three times a week (wk) without going over the maximum acceptable mercury intake amount for an average body weight pregnant person (i.e., mean body weight of participants who self-reported “pregnant” and “female”). The agencies determined the maximum acceptable intake amount by comparing the reference dose (RfD) developed by EPA to the predicted exposure from the consumption of different fish species. An RfD is determined to be a rate of exposure that a person can experience over a lifetime without appreciable risk of harm; however, the RfD for mercury is protective of neurodevelopmental effects from a critical window of development for a fetus during pregnancy. The RfD includes a 10-fold uncertainty factor to allow for variability among individuals and groups, including individuals who are not pregnant. By expressing the advice in terms of recommendations for weekly intake of fish based on the RfD, the agencies aim to help consumers reduce exposure to mercury, while also enabling them to achieve the health benefits from eating fish. We describe the equations and results for determining which fish we placed in each category below.

Equations for determining which category each fish went in

The boundaries for each category (or screening values) were calculated using equation 5-4 from EPA’s Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories, Volume 1: Fish Sampling and Analysis Third Edition (November 2000).

SV = (RfD*BW) / CR

where
SV = screening value for a noncarcinogen, microgram (µg) per gram (g)
RfD = reference dose, µg mercury per kilogram (kg) per day (d)
BW = body weight (kg)
CR = mean daily consumption rate of the species of interest (g/d)

For this fish advice, we used the screening value as the highest average amount of mercury in fish that would not exceed the reference dose at a given consumption rate. The consumption rate (CR) was calculated using the following equation:

Daily consumption rate (g/d) = serving size (ounce (oz)/serving) * (28.3 g/oz) * weekly servings (servings/wk) * (1wk/7d)

Factors used in the calculations

Reference dose for chronic oral exposure to methylmercury = 0.1 µg mercury/kg bodyweight / day. Taken from EPA’s Integrated Risk Information System (IRIS).

Body weight = 75 kilograms (165 pounds) = average weight of a pregnant woman. Taken from Table 8-29 of EPA’s Exposure Factors Handbook: 2011 Edition. This weight is supported by 2003-2010 NHANES data (2-day dietary recall) for pregnant women of 78 kilograms and coincides with average female adult body weight of 166 pounds from CDC's Anthropometric Reference Data for Children and Adults: United States, 2007–2010 (Oct 2012).

Serving size for adults = 4 ounces (113 grams) before cooking based on the FDA reference amounts customarily consumed (RACC) per eating occasion for fish and shellfish without sauce in 21 CFR 101.12.[1] The RACC for this category of food is 110 grams for uncooked fish. RACCs are used by manufacturers to determine their label serving sizes, which are used as the basis for nutrient declarations on Nutrition Facts labels on food packages.

Serving size is also consistent with the recommendation for those who are pregnant or breastfeeding of 8-12 ounces of a variety of fish per week from choices lower in methyl mercury found in the Dietary Guidelines for Americans and USDA’s My Plate. This is equivalent to 2-3 four-ounce servings per week.

Weekly servings = 1, 2, or 3

Table 1. Screening Values for Fish Categories

Weekly fish servings	Screening value (µg/g)	Chart category
0	> 0.46	Choices to Avoid
1	≤ 0.46	Good Choices
2	≤ 0.23	Good Choices
3	≤ 0.15	Best Choices

The screening value (Table 1 above) is the highest allowable average amount of mercury in fish at a given consumption rate. Therefore:

Highest allowable average mercury concentration in fish per serving when eating 3 servings per week = 0.15 µg/g. Any fish with an average mercury concentration less than or equal to 0.15 µg/g was placed in the “Best Choices – eat 2 to 3 servings a week” category.

Highest allowable average mercury concentration in fish per serving when eating 2 servings per week = 0.23 µg/g. In order to be protective, any fish with an average mercury concentration greater than 0.15 µg/g up to 0.23 µg/g was placed in the “Good Choices – eat 1 serving a week” category because it could not be eaten 3 times a week without exceeding the reference dose.

Highest allowable average mercury concentration in fish per serving when eating 1 serving per week = 0.46 µg/g. Any fish with an average mercury concentration greater than 0.23 µg/g up to 0.46 µg/g was placed in the “Good Choices – eat 1 serving a week” category. Any fish with an average mercury concentration greater than 0.46 µg/g was placed in the “Choices to Avoid” category.

Table of fish species, fish data, and weekly servings

We primarily used fish data from FDA’s monitoring database of mercury levels in commercial fish and shellfish (found at Mercury Levels in Commercial Fish and Shellfish (1990-2012) and Mercury Concentrations in Fish: FDA Monitoring Program) with support from other sources referenced below. All values for mercury are for fish before cooking except for those cooked during processing (e.g., canned fish) (Table 2 below). However, please remember that the fish advice recommends the consumption of only cooked fish for those who are pregnant; individuals who are pregnant should avoid eating raw fish. For those who are interested, mercury concentrations for cooked fish can be roughly approximated using the following formula: (μg mercury/ g uncooked fish) × (1 g uncooked fish/ 0.75 g cooked fish) × (28.3 g/ 1 oz)

For any fish species that had fewer than 30 samples in FDA’s dataset, we examined the following supplemental datasets: Karimi et al. (2012), EPA’s Mercury in Marine Life Database, EPA National Coastal Assessment (NCA): NCA/ National Coastal Condition Assessment (NCCA) data, Health Canada (2007), and a USDA-funded study by Cladis et al. 2014. We calculated the 95th percent confidence intervals on the mean for all fish species with available data based on a bootstrap analysis using the statistical software ‘R’ (library boot). We then considered whether the upper 95th percent confidence interval exceeded the screening value for that category. If the concentration for the 95th percent upper confidence interval fell in a different category, we looked at the means and sample sizes for that fish in those other datasets. If this supplemental data indicated a fish should change categories, then we moved it. If the supplemental data indicated a fish should remain in its calculated category, then we did not move it. If there were no supplemental data or if the sample sizes of that supplemental data were small, then we moved the fish based on the 95th percent upper confidence interval concentration. If the concentration for the 95th percent upper confidence interval did not fall in a different category but the supplemental data indicated a fish should change categories, then we moved it.

Table 2. Fish Species, Mercury data, and FDA/EPA Fish Advice Category

Fish species	Mercury concentration average (µg/g or ppm)	Mercury concentration 95% confidence interval (µg/g or ppm)	Number of samples	Fish category
Anchovy	0.02	0.01, 0.02	15	Best choice
Atlantic croaker	0.07	0.06, 0.08	90	Best choice
Atlantic mackerel	0.05	NC	80	Best choice
Black sea bass	0.13	0.10, 0.16	29	Best choice
Bluefish	0.37	0.33, 0.42	94	Good choice
Buffalofish	0.14	0.10, 0.19	17	Good choice
Butterfish	0.06	NC	89	Best choice
Carp	0.11	0.06, 0.16	14	Good choice
Catfish	0.02	0.01, 0.04	59	Best choice
Chilean sea bass/Patagonian toothfish	0.35	0.29, 0.43	74	Good choice
Clam	0.01	0.00, 0.01	15	Best choice
Cod	0.11	0.09, 0.14	115	Best choice
Crab	0.06	0.05, 0.09	93	Best choice
Crawfish	0.03	0.03, 0.04	46	Best choice
Flatfish (flounder, plaice, sole)	0.06	0.04, 0.07	71	Best choice
Grouper	0.45	0.38, 0.52	53	Good choice
Haddock	0.06	0.05, 0.06	50	Best choice
Hake	0.08	0.06, 0.10	49	Best choice
Halibut	0.24	0.20, 0.29	101	Good choice
Herring	0.08	0.04, 0.13	27	Best choice
King mackerel	0.73	NC	213	Avoid
Lobster	0.1	0.06, 0.14	22	Best choice
Mahi mahi / dolphinfish	0.18	0.14, 0.22	29	Good choice
Marlin	0.49	0.38, 0.60	16	Avoid
Monkfish	0.16	0.11, 0.21	11	Good choice
Mullet	0.05	0.02, 0.09	20	Best choice
Orange roughy	0.57	0.53, 0.61	81	Avoid
Oyster	0.01	0.00, 0.02	61	Best choice
Pacific chub mackerel	0.09	NC	30	Best choice
Perch, freshwater	0.15	0.10, 0.20	19	Best choice
Perch, ocean	0.12	0.08, 0.17	31	Best choice
Pickerel	0.09	0.05, 0.14	16	Best choice
Pollock	0.03	0.02, 0.05	95	Best choice
Rockfish	0.23	0.17, 0.30	19	Good choice
Sablefish	0.36	0.28, 0.45	26	Good choice
Salmon, canned	0.01	0.005, 0.02	19	Best choice
Salmon, fresh/frozen	0.02	0.02, 0.03	94	Best choice
Sardine	0.01	0.01, 0.02	90	Best choice
Scallop	<>	0.00, 0.01	39	Best choice
Shad	0.04	0.02, 0.06	15	Best choice
Shark	0.98	0.91, 1.05	356	Avoid
Sheepshead	0.09	0.06, 0.12	8	Good choice
Shrimp	0.01	0.01, 0.01	40	Best choice
Skate	0.14	NC	56	Best choice
Smelt	0.08	0.05, 0.13	23	Best choice
Snapper	0.17	0.12, 0.23	67	Good choice
Spanish mackerel	0.35	NC	109	Good choice
Squid	0.02	0.02, 0.03	36	Best choice
Striped bass (ocean)	0.07	0.04, 0.11	41	Good choice
Swordfish	1	0.95, 1.04	636	Avoid
Tilapia	0.01	0.01, 0.02	32	Best choice
Tilefish (from Gulf of Mexico)	1.45	NC	60	Avoid
Tilefish (from Atlantic Ocean)	0.14	0.11, 0.19	32	Good choice
Trout, freshwater	0.07	0.03, 0.12	35	Best choice
Tuna, albacore / white tuna, canned	0.35	0.34, 0.36	451	Good choice
Tuna, albacore / white tuna, fresh/frozen	0.36	0.32, 0.40	43	Good choice
Tuna, bigeye	0.69	0.56, 0.84	21	Avoid
Tuna, light, canned (includes skipjack)	0.13	0.12, 0.14	548	Best choice
Tuna, yellowfin	0.35	0.33, 0.39	231	Good choice
Weakfish/seatrout	0.23	0.18, 0.30	46	Good choice
White croaker/Pacific croaker	0.29	0.25, 0.32	15	Good choice
Whitefish	0.09	0.06, 0.12	37	Best choice
Whiting	0.05	0.03, 0.07	13	Best choice

NC = not calculated

Recommended serving sizes for children based on age

We recommend children eat 2 servings of fish per week from a variety of “Best Choices,” but the portion sizes should be smaller than adult portions and right for the child’s age and body weight.

Equations for determining children’s serving sizes based on the mercury reference dose

The maximum allowable fish consumption rate was calculated using equation 3-3 from EPA’s Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories, Volume 2: Risk Assessment and Fish Consumption Limits Third Edition (November 2000).

CR_lim=(RfD*BW)/c_m

where
CR_lim = maximum allowable fish consumption rate (g/d)
RfD = reference dose (µg mercury/kg-d)
BW = body weight (kg)
c_m = measured concentration of chemical contaminant m in a given species of fish (µg/g)

Factors used in the equations

RfD = reference dose for chronic oral exposure to methylmercury = 0.1 µg mercury/kg body weight/day. Taken from EPA’s Integrated Risk Information System (IRIS).

BW = average body weight for girls (kg) from CDC's Anthropometric Reference Data for Children and Adults: United States, 2007–2010 (Oct 2012) - Table 1, based on data from National Health and Nutrition Examination Surveys (NHANES)

C_m = the highest of the average mercury concentrations in fish in “Best Choices” category = 0.15 µg/g

The results were converted from a daily fish consumption rate in grams per day to a serving size in ounces per serving using the following equation and a weekly serving rate of 2 servings per week:

serving size (oz/serving) = (consumption rate (g/d)*7 d/wk) / (2 serving/wk*28.3 g/oz)

Table 3. Results - Child’s serving size if eating 2 servings per week from “Best Choices,” when serving size is based on mercury intake

Age (years)	Average female weight (kilograms)	Average female weight (pounds)	Serving size* (ounces) for child eating 2 servings of "Best Choices" (0.15 µg/g of mercury)
1**	10.9	24.0	0.9
2	13.4	29.5	1.1
3	15.7	34.6	1.3
4	17.7	39.0	1.5
5	21.1	46.5	1.7
6	23.6	52.0	1.9
7	26.8	59.1	2.2
8	31.9	70.3	2.6
9	35.5	78.3	2.9
10	41.1	90.6	3.4
11	47.5	104.7	3.9

* The amounts in this column are one serving of “Best Choices.” To calculate weekly amount of “Best Choices,” multiply the serving size in this column by 2.
** Added December 7, 2020 as a technical reference for use and development of the Dietary Guidelines for Americans, 2020-2025.

To prevent children from exceeding the RfD for mercury, these are recommended serving sizes (after rounding) of fish for various age groups when eating fish 2 times a week from the “Best Choices” category:

Age 2: 1 ounce per serving
Age 6: 2 ounces per serving
Age 9: 3 ounces per serving
Age 11 and up: 4 ounces per serving

Meeting the recommendations of the Dietary Guidelines for Americans while limiting methylmercury exposure to under the RfD for children

The FDA/EPA Fish Advice has not changed. The Dietary Guidelines for Americans, 2020-2025 now provides additional advice on feeding fish to children. For many children, the Healthy U.S.-Style Dietary Pattern in the Dietary Guidelines for Americans includes more ounces of fish per week than Table 3 above. If the amount that is recommended in the Dietary Guidelines Healthy U.S.-Style Dietary Pattern is greater than the amount in Table 3 above, providing the subset of “Best Choices” fish in the list below can limit methylmercury exposure to under the RfD. The 22 fish in this list are within the “Best Choices” category but are even lower in mercury to support that children can consume the quantities recommended in the Healthy U.S.-Style Dietary Pattern without exceeding the RfD:*

• Anchovy
• Atlantic mackerel
• Catfish
• Clam
• Crab
• Crawfish
• Flounder
• Haddock
• Mullet
• Oyster
• Plaice

• Pollock
• Salmon (canned, fresh, or frozen)
• Sardine
• Scallop
• Shad
• Shrimp
• Sole
• Squid
• Tilapia
• Trout, freshwater
• Whiting

*The list above are fish in the “Best Choices” category that are less than or equal to a mean methylmercury concentration of 0.07 ug mercury/gram of fish in cooked forms. This threshold can adequately limit methylmercury exposure to allow children to consume the weekly amounts of fish recommended by the Healthy U.S.-Style Dietary Pattern in the Dietary Guidelines for Americans while limiting methylmercury to under the RfD. The list includes the types of fish identified in Tables 2-1 and A3-1, Footnote E of the Dietary Guidelines for Americans, 2020-2025 that can be consumed at 3 ounces per week for children at the 700-1,000 calorie patterns for ages 1 to 3 years and also applies to ages 4 to 11 years when recommended amounts in the Dietary Guidelines exceed the amount of “Best Choices” in Table 3 above.

The following Figure compares ranges of weekly amounts of fish recommended by the Dietary Guidelines for American, 2020-2025 [2] to the amounts of “Best Choices” in the FDA/EPA Fish Advice (Table 3 above) and to the subset of “Best Choices” (bullets above) that can be consumed without exceeding the RfD for mercury. In all age groups, for at least some children, the amounts recommended by the Dietary Guidelines [2] exceed the amounts of fish from the “Best Choices” category that could be consumed without exceeding the RfD limit for methylmercury. In these cases, children can consume fish from the subset of “Best Choices” that are even lower in mercury (bullets above and listed in the Dietary Guidelines for Americans, 2020-2025 (Tables 2-1 and A3-1, Footnote E)).

Figure. Weekly Fish Consumption for Children – Dietary Guidelines for Americans Recommendations Compared to the FDA/EPA Fish Advice

In the Figure above,

• Dark blue bars are the range of amounts of fish in ounces per week recommended from Healthy U.S.-Style Dietary Pattern in the Dietary Guidelines for Americans, 2020-2025 for calorie levels specific to age, sex (males and females), and physical activity level [2].
• Light blue bars are the range of amounts of fish in ounces per week in the FDA/EPA Fish Advice based on the amount of fish that can be consumed from the “Best Choices” category without exceeding the RfD limit for methylmercury.
• Blue outlined bars are the range of amounts of fish in ounces per week from the subset of FDA/EPA Fish Advice “Best Choices” category that are even lower in mercury that can be consumed without exceeding the RfD limit for methylmercury. This subset list of fish is found above and in the Dietary Guidelines for Americans, 2020-2025 (Tables 2-1 and A3-1, Footnote E).
• The amount of fish in the FDA/EPA Fish Advice varies depending on a child’s body weight, where female body weights were used to be more health protective because girls generally weigh less than boys.

References

Cladis, D.P., Kleiner, A.C., and Santerre, C.R. (2014). Mercury content in commercially available finfish in the United States. J Food Prot 77, 1361-1366. Retrieved at http://www.ncbi.nlm.nih.gov/pubmed/25198598. FDA/EPA obtained the raw data from the study authors for analysis.

Health Canada. (2007) Human Health Risk Assessment of Mercury in Fish and Health Benefits of Fish Consumption, Bureau of Chemical Safety Food Directorate Health Products and Food Branch, Ottawa, Ontario, Canada.

Karimi, R., Fitzgerald, T.P., and Fisher, N.S. (2012). A quantitative synthesis of mercury in commercial seafood and implications for exposure in the United States. Environ Health Perspect 120, 1512-1519. Retrieved at http://ehp.niehs.nih.gov/1205122/.

U.S. Department of Agriculture and U.S. Department of Health and Human Services. Dietary Guidelines for Americans, 2020-2025, 9^th Edition, December 2020. Available at https://www.dietaryguidelines.gov.

U.S. Environmental Protection Agency (U.S. EPA). (2016), National Coastal Condition Assessment (NCCA) Office of Water & Office of Research and Development, EPA 841-R-15-006, Washington, D.C. 2010 Results. Retrieved at https://www.epa.gov/national-aquatic-resource-surveys/national-coastal-condition-assessment-2010-results.

U.S. Environmental Protection Agency. (U.S. EPA) (2016). National Coastal Assessment (NCA): Northeast 2000-2006 Summary Data. Retrieved at https://archive.epa.gov/emap/archive-emap/web/html/index-124.html.

U.S. Environmental Protection Agency (U.S. EPA) 2003. Mercury in Marine Life Database. Office of Wetlands, Oceans and Watersheds. Retrieved at https://cfpub.epa.gov/si/si_public_record_Report.cfm?dirEntryId=58213.

---

[1] The RACC we used was for entrees without sauce, e.g., plain or fried fish and shellfish, fish and shellfish cake. The RACC value for that category is 85 grams cooked, and 110 grams uncooked. We used the RACC value for uncooked fish as the serving size in our calculations. We did this because our mercury data for most fish are for uncooked fish.

[2] Estimated calorie needs depend on children’s age, whether children are “sedentary,” “moderately active” or “active,” and whether they are male or female. The Dietary Guidelines for Americans provides estimated calories needed for each age group that are based on the Estimated Energy Requirement established by the National Academies of Sciences, Engineering, and Medicine. The Dietary Guidelines also recommends children consume specified amounts of seafood per week (in ounces per week) based on their calorie needs. In developing this figure, FDA and EPA considered the calorie need ranges that the Dietary Guidelines provides for each age group and the amount of seafood consumption that the Dietary Guidelines recommends at different calorie levels. For example, for children ages 4 to 7 years, the Dietary Guidelines estimates that to maintain calorie balance females and males need between 1,200 and 1,800 calories per day, based on the Estimated Energy Requirements and depending on whether they are sedentary or physically active. For individuals with a calorie level of 1,200 per day, Dietary Guidelines recommends consumption of 4 ounces of seafood per week. For individuals with a calorie level of 1,800 per day, Dietary Guidelines recommends 8 ounces of seafood consumption per week. Therefore, the recommended fish consumption per week for the 4-7 year-old age group ranges from 4 ounces per week (based on 1,200 calories for sedentary females) to 8 ounces per week (based on 1,800 calories for active males).