Innspill til kapittel Healthy dietary patterns i NNR 2022

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The healthy dietary patterns include fish and some dairy products. These foods are the biggest sources for pollutants PCB and dioxines (in Norwegian diet, for example, despite Norwegians eat too little fish according to recommentations.)

Norwegian Authorities, The Norwegian Scientific Committee for Food and Environment (Vitenskapskomiteen for mat og miljø) have this report:

VKM Report 2022: 16 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

Citation of this report, page 28:

«Dioxins and dioxin-like (dl-) PCBs are lipophilic environmental chemicals with long half-lives.
We are exposed to dioxins and dl-PCBs mainly through consumption of foods with high fat content, like meat, dairy products and fish.

Exposure over the years and accumulation in the body may be of health concern.

In the newly published risk assessment from the European Food Safety Authority (EFSA, 2018) the tolerable weekly intake (TWI) was reduced from 14 to 2 pg/kg bodyweight/week.

According to the EFSA report, the European population is exposed to dioxins and dl-PCBs above the new TWI, and the main food contributors of dioxins and dl-PCBs are fish, seafood, meat, egg and dairy products.»

The chapter Dietary patterns – for the Nordic Nutrition Recommendations 2022 does not see anything about how dietary patterns and health outcomes are influated by these pollutants.

I ask NNR 2022 to answer the following 3 questions:

  1. How is the status in the other Nordic countries?
  2. Is it necessary and/or benefitial to consume these products just to get the relevant nutrients? The main food contributors of dioxins and dl-PCBs are fish, seafood, meat, egg and dairy products»

My suggestion is that it is the healthiest way to get relevant nutrients from supplements – instead of food with pollutants PCB and dioxines. The other sources of nutrients are:

–EPA and DHA omega-3 fatty acids from seaweed oils (EPA og DHA – they are only essensial for pregnant women, lactationg women and children younger than 2 years old).

–Vitamin D from syntetic Vitamin D supplement

–Iodine from supplement or/and enriched foods and salt

–Selen from paranuts, sunflower seeds and eventually supplements.

  1. If NNR 2023 finds that there are some risks or disadvantages of this choice (substitution of meat, dairy products and fish with alternative sources of including supplements for these nutrients), then:

Which of these foods (meat, dairy products and fish,) and in which amounts, should be choosen as recommended sources of EPA+DHA, vitamin D, iodine and selen?

Norwegians eat too little fish according to existing recommendations, and get too much PCB and dioxins. If Norwegians exclude meat, egg and dairy products, and increase amounts of fish up to recommended level og intake, will Norwegians get enough EPA/DHA, vitamin D, iodine and selen?

Read also: Miljøgifter i norsk mat: fisk, ost o.a. and Kosthold for gravide: kosttilskudd eller miljøgifter? and https://forskning.no/svangerskap-barn-og-ungdom-debattinnlegg/debattinnlegg-kosthold-for-gravide-kosttilskudd-eller-miljogifter/1163450