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Letter to the Food and Drug Administration Regarding Thimerosal in Vaccines

November 7, 2001

Bernard A. Schwetz, DVM, PhD
Acting Commissioner
Food and Drug Administration
5600 Fischers Lane
Rockville, MD 20852

Dear Dr. Schwetz:

The Cherab Foundation is supporting the Safe Minds letter of October 19 regarding the recall of infant vaccines containing thimerosal. The Cherab Foundation, headquartered in Gillette, New Jersey is devoted to verbal apraxia (or dyspraxia of speech) and related speech and language disorders. The condition can vary from severe speech restrictions to limited speech output, to speech which is unintelligible and difficult to decode, all depending on the level of difficulty experienced in coordinating oral movements required for sound and speech production.

The Cherab Foundation is concerned with the future of large numbers of students with disabilities who are in need of speech related services. For example, according to the New Jersey State Department of Education, Office of Special Education Programs, 38,797 students with disabilities between the ages of 3 to 21 were speech-language impaired during the year 2000. A total of 58,973 students from among preschool disabled, autistic, emotionally disturbed, multiply disabled, mentally retarded, etc., or 32.9% of total, required some form of speech-related service. These figures testify as to the high prevalence of some sort of verbal apraxia symptoms among a broad range of disorders involving the central nervous system.

Environmental organo-mercury compounds can cause deficits in speech and language, including complete loss of expressive language, articulation difficulties, sensory integration, and hypotonia, all common symptoms in apraxic children. Many of these symptoms are prevalent in children with autism. The CDC conducted a study based on a sample of 100,000 children in which they found a statistically significant correlation between thimerosal exposure and speech and language delays. (Verstraeten, T. "Risk of neurological and renal impairment associated with Thimerosal-containing vaccines", National Immunization Program, CDC, presented at the IOM Thimerosal Review meeting, July 2001).

The Cherab Foundation feels that since there appears to be ample supply of non-mercury containing vaccines to fully immunize all children, prudence dictates that the mercury-containing vaccines be withdrawn as soon as possible.
Thank you for your attention to this request.

Robert Katz, Ph.D.
Director of Research
Cherab Foundation

Letter to the Food and Drug Administration regarding the dangers to health of indiscriminate ban of 4 kinds of fatty fish from pregnant women and newborns due to possible high mercury levels:

 Dr. Marjorie l. Davidson,
 Center for Food Safety and Nutrition
 Food and Drug Administration
 Washington, D.C.
 Dear Dr. Davidson,
 Please forgive my unsolicited appeal to you. But a recent FDA
 advisory recommending limited consumption of specific fish (shark,
 swordfish, tilefish and king mackerel) by pregnant women, due to
potentially high mercury levels has relevance for fish oil supplements
marketed for their omega-3 oil content. In regard to fish oil supplements the population at large does not know that MeHg binds to proteins and therefore it is not of concern in highly purified fish oils. They also have relevance for fish consumption decisions of the population at large. These recommendations come at a time when the American Heart Association recommended the consumption of two fish
meals per week (preferably fatty fish) to the general population as a
means of omega-3 fatty acid intake and reduction of risks from
cardiovascular disease. The FDA recommendations could
discourage pregnant women from consuming perfectly healthy oily fish
and this could jeopardize their intake of omega-3s, specifically DHA
essential for the fetus's brain development and the mental
health of the mother.

I am asking a simple question. Given that the Omega-3 Research
Institute, Inc., (O3RI) has already established a program to provide
high quality oils for clinical trials (see, could O3RI be of assistance to the FDA in clarifying the implications of the above FDA recommendations for the general public? For example:  through a specific educational program and/or through establishment of a clearinghouse for information on environmental toxins in fatty fish and perhaps fish oil supplements, etc.

The public is reacting in a panic mode, especially because medical
professionals, OBGYNs, pediatricians and cardiologists are
discouraging the public from eating fish. I heard recently a medical
call-in radio program in which a cardiologist, involved with nutrition and physical exercise was discouraging the listeners from eating fish with the rhetorical question: "Why would you want to store mercury in your body?" The interviewer's response to that was: "We should remember that, it is good advice".
It would be very unfortunate if regulations meant to preserve the health of pregnant mothers and their developing embryos and fetuses would result in an aggravated omega-3 essential fatty acid deficiency harming the developing fetus brain and eye development, the newborn, the developing child and the mother. In essence it could harm the entire population by endangering the cardiovascular health of those who are above 40 years of age and prone to coronary heart disease.
Please let me know if I can be of any assistance to you in avoiding
potential undesirable side effects to the recent well meaning ruling.
 Robert Katz, Ph.D.
Director of Research
Cherab Foundation
 Omega-3 Research Institute, Inc.
 3 Bethesda Metro Center, #700
 Bethesda, MD 20814
 Tel: 301-961-1918
 Fax: 301-417-9087
 Web URL:

The Cherab Foundation is a world-wide nonprofit organization working to improve the communication skills and education of all children with speech and language delays and disorders. Our area of emphasis is verbal and oral apraxia, severe neurologically-based speech and language disorders that hinder children's ability to speak.

The Foundation is committed to assisting with the development of new therapeutic approaches, preventions and cures to neurologically-based speech disorders. We bring together parents and medical, research, and educational professionals. Please join us and help to give our children a smile and a voice.

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Cherab Foundation
Communication Help, Education, Research, Apraxia Base
P.O. Box 8524
PSL, Florida 34952-8524
Phone: 772-335-5135

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Last Update: February 19, 2003