• On November 19, 2024, FDA issued a request for information on per- and polyfluoroalkyl substances (PFAS) in seafood in an effort to understand the potential for PFAS exposure from seafood and reduce dietary exposure to PFAS that may cause a health concern. According to FDA, seafood presents a unique challenge and opportunity to prevent contamination because many potential hazards can be introduced at the source, such as in growing areas, aquaculture farms, and on fishing vessels.
  • For purposes of this request, FDA defines “seafood” as fresh or saltwater finfish, crustaceans, other forms of aquatic life (e.g., alligator) other than birds or mammals, and all mollusks, which are intended for human consumption. Testing of samples in the general food supply has indicated that seafood may be at higher risk for environmental PFAS compared with other types of food. To expand on the results of these samples, FDA collected additional seafood samples of the most commonly consumed seafood in the United States, including clams, cod, crab, pollock, salmon, shrimp, tilapia, and canned tuna, most of which were imported. Based on perfluorooctanoic acid concentrations in canned clams from China, FDA concluded that their consumption is likely a human health concern, resulting in two voluntary recalls of canned clams from China.  Thus, FDA is requesting information to help enhance the Agency’s knowledge about the types of seafood prone to accumulate PFAS and harvest locations with PFAS contamination, ultimately supporting a comprehensive approach to advance clean air, water, and food.
  • Specifically, FDA is seeking data and information regarding PFAS concentrations in seafood, the environment, and processing water, as well as mitigation strategies for PFAS in seafood. FDA has provided specific questions for each of these categories to help identify where PFAS has been observed. The request for information will be published in the Federal Register on November 20, 2024, with a 90-day comment period ending February 18, 2025.
  • Comments can be submitted electronically on Regluations.gov to docket number FDA02024-N-4604. Keller and Heckman will continue to monitor developments in this area.