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When Norwegian Scientific Committee for Food and Environment, VKM, made their report/assesment of risk and benefits of fish consumption, they used data material from another 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/

In their report about risk benefit analyses of fish consumption, VKM has not considered/looked at the possibilities of achieving the same positive health effects of the long-chain omega-3 fatty acids EPA and DHA, by replacing fish oil supplements (or fish), with the same EPA and DHA from algal oils.

The long-chain omega-3 fatty acids EPA and DHA supplements made of algae oil is becoming more common and available. Algae oil contains exactly the same substances as fish oil do – EPA and DHA.
The long-chain omega-3 fatty acids EPA and DHA accounts for many of the positive health effects of fatty fish. Unlike fatty fish or fish oil, these do not contain any environmental toxins. That’s because they are grown in closed systems/tanks, like pools on land.

Not much research has been done on this, but the authorities should consider this.
Considering environmental toxins in fish and fish oils, as well as in dairy and meat, it is important to compare following:
How the health effects of EPA and DHA from fish oil would be affected if one replace these with algae oils, that containes accurately the same long chained fatty acids EPA and DHA.

Les også: Miljøgifter i norsk mat: fisk, ost o.a. og Flerumettet – sunt fett, bra for hjerte

specific comment

I suggest that you write following in the Introduction, page 2:

“Fatty fish, together with milk and dairy, and meat, is the main source of environmental pollutants, or toxins – dioxins and dioxin-like PCBs – in the Norwegian diet. These are fat-soluble and highly toxic organic pollutants that accumulate in the food chain, and end up in animal feed and then in foods (fish, dairy and meat) of animal origin, because they are in the environment. The Norwegian population is exposed to more dioxins and dioxin-like PCBs from food than the EFSA’s upper tolerance limit (which has been recently changed/increased).

Fish and other seafood in Norway account for over 40% of exposure in Norway, while around 25% comes from dairy products, according to Figure 1 in the article on environmental toxins and health at Norwegian Institute of Public Health.

Dioxins and dioxin-like PCBs in food do not cause acute health effects. But accumulation in the body (adipose tissue) over many years can cause disease.
These environmental toxins, which exists in fish, dairy and meat, are being stored in the fat tissue of women, and are transferred from mother to fetus. Then they are excreted in breast milk, together with fat from storages in woman’s body.

Children are exposed to larger amounts of environmental toxins, before birth (as fetus) and then with breast milk, like other toxic substances in the mothers blood, such as medicines, nicotine, alcohol and more.

Replacement of fish oil with algae oil

Fish and fish oil is important source of the long-chained omega-3 fatty acids EPA and DHA. It is actually EPA and DHA that accounts for many of the positive health effects of fatty fish.

But fish is not the only source of EPA and DHA. Algae oil contains exactly the same substances as fish and fish oil do – EPA and DHA. Supplements made of algae oil, The long-chain omega-3 fatty acids EPA and DHA Supplements made of algae oil are becoming more common and available.
Unlike fatty fish or fish oil, algae oils do not contain any environmental toxins. That’s because they are grown in closed systems/tanks, like pools on land.

Therefore, the authorities should make an assessment of how the replacement of fish oil (long-chained omega-3 acids EPA and DHA accounts for many of the positive health effects of fatty fish and fish oil). This is not made in VKM’s risk benefit analyses of fish consumption

Per today there is no any arguments against that thew EPA and DHA from fish oil is better than EPA and DHA from algae.
Not much research has been done on this replacement, but the authorities should consider this.
Considering the negative health effects of environmental toxins in fish and fish oils, as well as in dairy and meat, it is important to do such research and assessment.”

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

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