VEGA responds to an FSA consultation on advice on fish consumption
VEGA's response to the consultation on the review of the FSA's advice on fish consumption follows:
1. Songs of the sea and the romance and drama of sea-faring furnish material for legend and strife. The construction of fishing boats, the rigs of sailing boats for their various purposes and the thrifty application of the wind, waves, and the tides are attractions of increasing importance as alternatives to fossil fuels, and mainly land-based resources such as coal, oil, and nuclear power and dwindling resources from fields tapped from supplies under the bottom of the sea. Fishing fleets continued to operate from ports around the North Sea and off the western and southern waters of the shores of England. The trawlers, being made mainly from wood, did not set off mines and the form and rigs of British and French fleets allowed mingling and maintenance of a link between England and France, even after the surrender of France, with the similar languages of Brittany and Wales, a bond the enemy could not penetrate. Stories in the traffic of spies and agents were colorful and the intelligence and knowledge in the fishing fleets, augmented by the experiences of sailing boats for pleasure, was of great significance in the operations of the "reserve" Navy and preparation for the D-day landings in Normandy.
2. Fish-and-chips has been the demotic staple, possibly augmented with mushy peas and vinegar, from the postwar Depression of the 1920's and through the years of WW2. Fish has entered the vocabulary and mythology and symbolism in guises such as "fish is good for the brain" and "this is a fine kettle of fish" and history and fable, as in the miracle of the loaves and fishes. In evolutionary terms our forebears seem to have made use and become reliant on marine organisms, from fresh, brackish, or salty waters, and from plant life and shore-lines. The recurring question arises: were the Neanderthals extinguished because they did not, perhaps for climatic conditions, utilize the resources of the inshore seas and so succumbed to severe nutritional and reproductive deficiency, or they became exposed to a threat of disease associated with Acts of God or, latterly, with man-made mischiefs.
3. The term aquaculture must embrace activities and production of commodities used for manufacturing, processing aids for the food industry, and ingredients for supplements, as well as biofuels and wind-farming from fields where such outputs can be combined with in-shore fishing or cultivation of algae; in oriental countries such combinations may include using paddy fields growing rice as ponds for rearing fish stocks, and estuaries may be cleared of water hyacinths by means of herbivorous marine grazing animals such as manatees and dugongs (however, slaughtering and eating such mammals - which are mermaid like - might be more than the British public, hardened to the relentless cruelty to the dairy cow, would stomach). Production of shell-fish is accompanied by enormous "wastes" of chitin, for which many other by-products are finding lucrative use in health-foods and for manufacturing; and in terms of the environment and animal welfare and politics, commercial exploitation of whaling and killing of seals must be counted as subjects for the FSA's supervision of claims, labelling of provenance, and practice of due diligence (including industries using the co-and by-products for purposes other than food).
4. The FSA's reservations over sea-foods and the products of aquaculture may be listed as follows:
4.1. Pollution from agricultural run-offs and use of toxic substances for marine purposes. It would include the notorious endocrine disrupters
4.2. Presence of residues of heavy metals such as mercury, cadmium, and lead as a result of human activities. Some apparent risks may be over-rated: presence of arsenic, for instance, may be a natural accumulation of the element in an innocuous speciation such as a hi-valency chelated or betaine form.
4.3. Development of toxins by "natural" processes such as climatic and environmental changes with red tides and content of blue-green algae and highly poisonous substances such as tetrodotoxin and saxitoxin. Scombroid infections are associated particularly with fish of the mackerel type.
4.4. Certain allergies have developed as skin rashes in handlers of fish, eg Dogger Bank Itch. The practice of fishing at sea and even as angling in rivers and streams in rural England is associated with dangers and wounding to the predators. Some coarse fishing (catch and return) is not primarily aimed at food production. Fishing in its many forms represents crude (and increasingly intensified and industrialized forms of hunting for food; however, the enormous challenges in farmed fishing evoke objections to a fate like that inflicted on birds bred, reared, and exploited for eggs and to yield oven-readies).
4.5. The "ozone" of our coastal shores may not be as sweet as sunny pictures of rocky pools suggest. The Gaia theory of the Earth recognized a blanket of sulfurous compounds brought to the surface of the oceans, and further research has indicated that the smell of rotting seaweeds may indicate the presence of halogenated hydrocarbons to be counted as undesirable components among the greenhouse gases.
Nutritional and environmental topics that remain for consideration are:
5.1. Vitamin D - A hot topic in nutritional research
5.2. The eicosanoid balance: the omegas and DHA and EPA
5.3. Nutrients (other than vitamin D). These could include protein/calorie nutrition, calcium, iodine, selenium, and vitamin B12 and vitamin A
6. In our VEGA NEWS, we published about 5 years ago and available on our website some guidance in developments in the significance of vitamin D in the prevention of osteopenias and involvements in other organs with the appropriate receptors in the muscular and skeletal system, the gut, vasculature, CNS and brain. These forecasts have been amply borne out: indicators such as the prevalence of rickets, immigrations, and melanomas, and need for special attention directed to adolescents, elderly populations, to people who avoid the sun or are denied access to it and to abstainers from fish foods because of the taste or for vegetarian aversions. A fashion for increasingly powerful sunscreens and even changes in the open air nursing in the medical book saw not only signs of moderate deficiency, but also reintroduced doctors and the social services to frank rickets, and the need for taking out court orders for removal of their babies from parents who were following dietary regimens of extreme vegetarianism ag
gravated by adherence to other severe disciplines such as macrobiotics and raw food principles.
7. The issues that attract our research at the moment and on which we could expand at the moment are:
7.1. The tests available to doctors and nurses on the NHS and are available to the public lack comprehensive and definition. Full interpretation for screening purposes or treatment of individual patients would need to measure, even in the context of bone disorders, blood levels (and appropriate dietary intakes) of calcium, magnesium, "vitamin D", parathyroid and thyroid hormones, and vitamin K and calcitonin. At present, the tests for "vitamin D" measure intermediate pre-hormone substances for the finally active vitamin calcitriol, which is not very stable: it can be used cautiously in medical procedures.
7.2. Although medical and pharmaceutical tests available to doctors and nutritionists insist that vitamin D2 and D3 are equivalent, they report equivalence in biological action, which now needs amendment, even when the effects on bone chemistry alone are considered. They could still be important in this function according to the method of administration (eg by mouth or injection). The labelling on foodstuffs does not always specify anymore than a "vitamin D" content with no suffixes. Some blood tests record measurements distinguishing the precursors; doctors are offered advice on interpretation by endocrinologists.
7.3. Vitamin D - the Sunshine Vitamin - is derived from animal sources, eg exposure to the human skin, in the D3 (cholecalciferol) form. Vitamin D2 derives from ergocholesterol, a steroid in yeasts, related biochemically to cholesterol in animals, in a pathway of biosynthesis from which statins are also produced; vitamin D2 is therefore called ergocalciferol. Vitamin D3 is formed, like vitamin D2, in the last stages of a synthesis that uses chemical processes and irradiation in the final steps to cholecalciferol in this case; calcitriol also belongs to the D3 series. Other compounds are involved in the essential hydroxylations and photo-activated molecular changes in this chemistry; their significance is not clear at the moment.
7.4. The difference between D2 and D3 is marked in poultry, the former being almost inactive. Intensively-reared livestock need supplementary vitamin D, given in the rations in the D3 forms. Cattle become skittish as they are released for the spring turnout to pasture and thus exposure to "natural" sunlight; this is reflected in levels of vitamin D3 in summer milk and butter. Intensively-reared poultry depend entirely on their rations for vitamin D, which will come through in their meat and eggs in the D3 form. Birds ingest vitamin D by preening themselves on wax deposited on their feathers and then irradiated by the sun and ingested (birds differ from mammals in that their bones are hollow; poultry are being bred for such big yields of heavy breast meat - to the point where copulation is impossible - that they suffer from deformities and pain affecting their gait and susceptibility to fracture. The legs may still have some meat on them and they find a market in exports to China. Animal welfarists might also seek explanations for the feather-pecking that breaks out in "free range" flocks as an expression of the need for the products of biosynthesis in other birds in the flock.
7.5. Vitamins A and D are described as fat-soluble vitamins in text books and the biochemical tests are based on this property. However, this may overlook some conflicting facts in the case of vitamin D, which could be modified by a process called conjugation (as a sulfate or a molecular combination with a sugar), thus being rendered water-soluble and missed in the standard test. For some time this explanation was adduced to account for the low content of the vitamin in human milk. However, the observation has been proven to be correct and early excessive attempts to supplement baby milks harmed the babies. These findings tend to support theories of migration of our forebears of a tropical stock of genes still yearning for the sun as we migrate southwards for the sunshine - at the risk of melanoma in our fair skins. All these factors combine to emphasize epigenetic influences during gestation, especially for prems. It is also relevant to note the tendency for "natural" birthing in subdued lighting and concealment and abandonment of strong light to facilitate the correction of brown babies whose livers have not awaken to the metabolic demands expected of them.
7.6. The belief that vitamin D activity - and in the D3 series at that - is derived only from animal sources has been demolished by evidence and proof in the veterinary sector. Calcinosis in ruminants has been traced to consumption of Solanum malacoxylon and Trisetum flavescens (golden oatgrass). The latter occurs in British pastures with no reported indications of toxicity in livestock nor of consumption or use by humans. The active principle has been identified as the highly active calcitriol; the evidence fits well and indicates that permission for general commercial purposes could be obtained without years of testing or evidence of a tradition of sustained human consumption somewhere in the world. This could be a fascinating research project, filling gaps and applications in botanical and nutritional knowledge. New biosynthetic systems might be discovered and possibilities in achieving the desired ends by irradiating whole plants or parts might improve chances of commercial development and applicat
7.7. It would also ease the consciences of animal welfarists and vegetarians who are reluctant to use products of animal origin. Lanolin (wool wax) is obtained, mostly in China, in washings of fleeces of sheep for the production of cholecalciferol. The wool is obtained when sheep are sheered seasonally to relieve the effects of overheating in the summer season. Some may derive from skins of slaughtered animals. Shearing can be regarded as being consistent with the animals' welfare, but the procedure and handling can be rough and stressful; and the Lord does not always "temper the wind for the shorn lamb." Vitamins declared among the ingredients of a food (as a fortification) or supplement may be presented to patients with an osteopaenia (eg rickets and osteoporosis) by formulations made from ingredients (such as gelatin) "against their principles" and embarrassing doctor / patient relationships). People such as veggies, Muslims, Jews, and Hindus can now ask the prescribing pharmacist to provide acceptable alternatives, which may be augmented with magnesium, calcium and vitamin K with no embarrassment in the enhancement. There remain for the labelling, advice on RDAs and warnings about overdosing. As serious health issues arise in these matters, especially for children and women of child-bearing age and the aged housed in institutions, that they may have to resort to vitamin D3, for which far more evidence in use is accumulating, notably the inadequacy of D2 in farming situations.
7.8. We urge the FSA to support such research and interpret the results. Our own researches lack adequate funding. Doctors need education and they and surgeons must heed advice on the participation of the thyroid and parathyroid glands and maintenance and performance, especially in processing outputs of the appropriate hormones (there remain doubts over the need to assure continued secretion of calcitonin). Resort will increasingly be made to non-invasive methods such as magnetic resonance imaging and ultrasound to measure bone mineral density (BMD), and people and doctors' surgeries could usefully keep series of records of height. Patients will face challenges in the keeping of dates for screening purposes and for genetic counseling and epidemiology and finally for the pathologist for autopsies. As always, read and discuss what's on the label and remember that pharmacists are generally well-informed.
7.9. Fluoride has escaped much attention and controversy lately. In a haphazard way, the risks to the integrity of bones, teeth, and skin seems to have been resolved.
7.10. Shiitake mushrooms have been mentioned from time to time as plant sources of vitamin D activity due to components of the D3 type and with appropriate levels of hydroxylation and conjugation. We are looking urgently into this and seeking collaboration with the food industry and academic mycologists. We have also drawn attention to the Advisory Committee for the Microbiological Safety of Food for a project underwriting an exciting application of food technology to compensate for the hours spent on the grottier aspects of hygiene, which scientists should prefer. Reports of the corresponding advisory committee on novel foods and products would be worthwhile. However, recent reviews of academic research draws attention to Britain's decline in this area of competence. We hope that the FSA will remedy this situation. Shiitake mushrooms are available commercially. Oyster mushrooms are also widely available; they are credibly regarded to have statin-like activity, as have other products of acceptable fermentations in the orient. Mycoproteins such as Quorn come into this category. The media for such fermentations can be based on simple inorganic sources.
The Omegas and the Eicosanoid Balance
8. As with vitamin D the significance of fats of marine origins (vitamin F) have acquired new importance giving support to the adage that "fish is good for the brain". However, in recent advances into the consumption of long-chain fatty acids (and esters) and the significance of chain length, degree of hydrogenation (ie. saturation) and configuration of double bonds (cis or trans) desirability of very long polyunsaturated fatty acids VLCPUFA's from fish in the diet has received acclaim, muted only by misgivings over pollution (by water-and fat-soluble substances) in marine and other sources of water likely to be contaminated as a result of human activities.
9. The edible fish derive the desired compounds by consumption of other fish and all of them depend on "plant" sources with primitive biochemistries to generate the required fatty acids, called eicosanoids and principally DHA and EPA via compounds with shorter chains and less unsaturation, these being generally included in the bracket of omega-3s, omega-6s, and omega-9s. Modern diets tend to raise the ratio of omega-6s to omega-3s undesirably, an imbalance notable in people who eat fish rarely, because of the taste and memories of cod liver oil and liver in their youth (to correct deficiencies of the fat-soluble vitamins A and D) and because of the environmental and animal welfare objections to the crimes committed in the cruel seas and even in the brooks streams, rivers, and lakes in otherwise green and pleasant lands.
10. Therefore, we are watching alternatives, some of which are undergoing vigorous research, which we can list below.
10.1. Replacement in cuisines of the species being fished to extinction with substitutes of fast growing and reproducing species. Problems of pollution remain.
10.2. Replacement of wild catches by intensive farming in inland and coastal waters. All the problems, inefficiency, pollution, and cruelty that attend poultry production are repeated, including the common violation of the Grow Food, not Feed principle. Nonetheless, some animal welfarists, "organics" and cookery writers are turning a blind eye to it - the same vision that can blot out the cruelties perpetrated in the production of oven-ready poultry and eggs from intensively-reared birds.
10.3. Cultivation of the plant sources of the biomass on which fish and humans could derive their omegas and carotenoids. This possibility is being realized by intensive cultivations in ponds or vats. The products are already being added to some baby foods and, in America, to soft drinks. We have already suggested to the food industry additions of such products to plant-milks. The "marine" flavor remains enough to cause some reluctance over such additions, and the choices of enhancements of foods could be more careful than to soft drinks.
10.4. Searches are going ahead vigorously with terrestrial plants that may have the elements of the biosynthesis of the required VLCPUFAs or that could be induced to provide after introduction of the genes to establish the full marine complement (ie effectively to reverse evolution and render them primitive organisms). Part of the Lipgene project, which is coming to an end, is directed to this purpose. Monsanto in the USA claim to have achieved the necessary GM in soya, presumably to use as feed for poultry to pass on the required nutrient values to consumers of eggs and meat. This ploy might lessen regulatory controls on direct use for human consumers moving towards cruelty-free eating plans, (and provided that they accept the GM and the fortification of food and resort to supplements so designed).
There are further alternatives in which plants with special genetic and exploitable properties, eg of biosynthesis with the precursor stearidonic acid and prospects with common plants, eg echium, representing the family to which the herb and garden plant viper's bugloss belongs. There may even be in some plants a salvage alternative biosynthetic pathway.
10.5. Such developments would avoid the many objections in relying on fish for balancing human intakes of the eicosanoids and provide means of improving the omega ratios while retaining the benefits in fat intakes for normal purposes of eating. We are keen to utilize crops, possibly neglected from farming and years ago, that can be grown by British farmers, horticulturalists, and foresters, as well as the operators of modern technologies.
Vitamin B12, Animal Protein Factors etc
11. Discovery in 1945 of vitamin B12 as the pernicious anemia factor left solutions to other challenges, such as the animal protein and fish soluble factors, to be resolved and thus to liberate the full flowering of vegetarian thought, practice, and symbolism, which looked forward to a meat-free, dairy- free, and cruelty-free set of standards of for eating plans. Later developments confirmed this promise, but the longstanding reliance on fish undermined some of the assertions and applications, certainly if reservations over supplements and fortification could be overcome, especially in the proselytizing by vegan zeolots.
12. Our own research and others' clarifies matters over intakes by the public of sources of iodine and on the functions of the thyroid gland. Labelling of foodstuffs, attention to populations most at risk of developing deficiency (or excessive intakes), and possibilities are matters receiving attention and screening. However, we believe that the FSA should listen as intently to the evidence we have collated, which applies to the general population and labelling of foods, as to the ardent vegan population. We recommend that sea vegetables should count among the esteemed Five and that commercial development in sales and applications be fostered; this means greater emphasis in data in composition of food tables, recognizing usage in food technology as processing aids (eg carrageen, agar, and alginates), and improving labelling.
13. As thyroid function is especially important for development of the brain in the unborn baby and near term and for the mood and self-confidence in the elderly we are giving these matters great attention and recommending revisions of literature by the BMA and sold in pharmacies. We have again to note the greater attention paid in the EU on thyroid function, iodide supplies of food and water, and on the possibilities in screening non-invasively, eg with ultrasound, and lessons that we can learn from veterinary practice and from scientific meetings.
14. Goitrogens in common vegetables, cereals, and pulses may increase in significance as these components of foodstuffs become more important in healthy eating plans. Gaps in composition of food tables may conceal factors or, on the contrary, miss substantial contributions, even exceeding safe concentrations. Not only may components of additives and supplements exert these effects, but medical practices, eg with X-ray contrast agents and treatments with drugs such as amiodarone. Adoption of a vegan diet can effectively deplete the body's stores of thyroid factors in preparation for radioactivity treatments to ablate cancerous tissue. Stores of potassium (or iodate) are held round the country for washing out normal accumulations in the gland as a result of nuclear fallout.
15. Erythrosine is a coal-tar red dyestuff used to color many foods with strawberry or raspberry flavors. It is a rich source of iodine; it could be a component of breakdown products rich in assimilable iodide. We are collating evidence on the factors and filling gaps in the food tables. The FSA has a duty to remove confusions over iodized salt and supplementations and variations in use and practice.