Marie McCormick, MD, ScD
Immunization Safety Review Committee
Institute of Medicine
National Academy of Sciences
2101 Constitution Avenue, NW
Washington, DC 20418

 Dear Dr. McCormick:

I am the president and founder of the Cherab Foundation, headquartered in Gillette, New Jersey, which is one of the largest national nonprofit organizations devoted to verbal apraxia (or dyspraxia of speech) and related speech and language disorders. (See Attachment 1). Developmental verbal apraxia is an inability to plan and perform certain motor speech tasks. 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. (See Attachment 2). 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. (See Attachment 3.) 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. In this context I have become aware that infant vaccines used to contain mercury through a preservative, thimerosal.  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).

Given the above, I wish to bring to your attention a new, potential therapeutic intervention in verbal apraxia that consists of essential fatty acid (EFA) supplementation.
An analysis of professional anecdotal case reports provided by speech pathologists was presented to a scientific panel of experts at a CHERAB Foundation emergency fact finding conference held on July 23-24, 2001 in Morristown, New Jersey. The analysis
clearly indicated improvement in verbal expression abilities of supplemented subjects. (See Attachment 4). Additional anecdotal reports presented by a practicing developmental pediatrician and a speech therapist provided additional proof of initial success. In a post-conference statement, the scientific panel of experts unanimously agreed that the existing scientific evidence justifies planning and implementing a comprehensive clinical trial to convincingly validate this new potential therapeutic intervention and discussed various clinical research alternatives to achieve this validation. (See Attachment 5). 

I am the parent of a son with verbal apraxia who benefited from the EFA supplementation and I can personally testify as to its effectiveness. Personal testimonials of other parents are also attached. (See Attachment 6).

Our organization is looking closely at the possibility that organic mercury compounds might be causing some cases of apraxia and feels that more good research is needed to explore and assess the potential associations between verbal apraxia, EFA supplementation and organo-mercury compounds. New therapeutic interventions in verbal apraxia with EFA supplementation should also be pursued, since they could be effective in alleviation of symptoms in other neurodevelopmental disorders such as autism spectrum disorders, sensory integration disorder and hypotonia where organo-mercury toxicity might have been involved.

Sincerely,

Lisa Geng
President CHERAB Foundation
http://www.apraxia.cc

Letter to the Food and Drug Administration regarding thimerosal in vaccines:

 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 http://www.omega3ri.org ), 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.

 Sincerely,

 Robert Katz, Ph.D.

Director of Research
CHERAB Foundation

President
Omega-3 Research Institute, Inc.
3 Bethesda Metro Center, #700
Bethesda, MD 20814
Tel: 301-961-1918
Fax: 301-417-9087
E-mail: omega3ri@aol.com
Web URL: http:// www.omega3ri.org