Innspill til NNR-kapittelet om omega-3 fettsyrer

Long chained omega-3 fatty acids EPA and DHA are responsible for many positive health outcomes. But fish and fish oils contains PCB and dioxines – which are fat-soluble and highly toxic organic pollutants that accumulate in the food chain, and end up in fish and other animals, including humans.

Fish oil produces try to clean their oil from these toxines, but some amount of toxines is present,
nevertheless.
Fish and other seafood in Norway account for over 40% of exposure in Norway (Norwegians consumes most fish in the Nordic and Baltic countries).
It is therefor important to assess whether algae oil instead of fish oil and fatty fish could give some of the same (or similar) health outcomes.

Norwegian Scientific Committee for Food and Environment, VKM published in 2022 to reports, one – assesment of risk and benefits of fish consumption.
And the other report “Risk assessment of dioxins, furans and dioxin-like PCBs in food in Norway. Scientific Opinion of the Panel on Contaminants of the Norwegian Scientific Committee for Food and Environment.”

The VKM says following, as summary of the report “Risk assessment of dioxins, furans and dioxin-like PCBs in food in Norway”, quoted:

“Dioxins and dioxin-like PCBs are difficult to break down, fat-soluble and highly toxic organic pollutants that accumulate in the food chain. They end up in animal feed and food because they are found in the environment.
Dioxins and dioxin-like PCBs in food do not cause acute health effects. It is primarily the amount in the body after accumulation over many years that can cause health damage.”
“The food groups that contribute the most are fatty fish, milk and dairy products, and meat.” “On average, the Norwegian population is exposed to more dioxins and dioxin-like PCBs from food than the tolerance limit.”

Source:
Norwegian Scientific Committee for Food and Environment (VKM 2022). Dioksiner i maten til den norske befolkningen – Dioxins in the food of the Norwegian population
https://vkm.no/risikovurderinger/allevurderinger/dioksinerimatentildennorskebefolkningen.4.413ea92416707dc4375a0a18.html

VKM. Risk assessment of dioxins, furans and dioxin-like PCBs in food in Norway. Scientific Opinion of the Panel on Contaminants of the Norwegian Scientific Committee for Food and Environment. Helle Katrine Knutsen, Heidi Amlund, Jonny Beyer, Barbara Bukhvalova, Dagrun Engeset, Inger Therese Laugsand Lillegaard, Espen Mariussen, Gro Haarklou Mathisen, Anne Lise Brantsæter, Sara Bremer, Ingunn Anita Samdal, Cathrine Thomsen, Gunnar Sundstøl Eriksen (2022). VKM Report 2022:16, ISBN: 978-82-8259-391-5, ISSN: 2535-4019. Norwegian Scientific Committee for Food and Environment (VKM),
Oslo, Norway

EFSA. Risk for animal and human health related to the presence of dioxins and dioxin-like PCBs in feed and food https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2018.5333
Scientific Opinion on the risk for animal and human health related to the presence of dioxins and dioxin-like PCBs in feed and food. EFSA Journal 2018;16(11):5333, 331 pp. https://doi.org/10.2903/j.efsa.2018.5333
EFSA CONTAM Panel (EFSA Panel on Contaminants in the Food Chain), 2018.

Environmental toxins and health – FHI, Norwegian Institute of Public Health https://www.fhi.no/ml/miljo/miljogifter/fakta/dioksiner-og-dl-pcb-faktaark/

5.Spesific comments to the chapter

I suggest writing following on page 35 or 36 (or another page):

Long-chain omega-3 fatty acids EPA and DHA is traditionally associated with fish oils. However, oil from algae (algae oil) contains exactly the same EPA and DHA as fish oils and fatty fish. Today, algae oils as supplement to EPA and DHA are on the market. They are produced on land, in closed systems/tanks, and are therefore completely free of environmental toxins – unlike fish and (to a lesser extent) fish oils.

As oily fish is the largest source of PCBs and dioxins (environmental toxins) in the Norwegian diet, and because the tolerable level/limit has already been exceeded in the Norwegian population,

it is important to research and assess the following:

To what extent can the replacement of fish oils (and fatty fish) with algae oils can provide the same positive health effects as EPA and DHA from fish and fish oil.

Fish consumption in Norway is the highest in the Nordics and the Baltics, so this could be relevant for all the other countries in the region as well.