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TESTIMONY by
Andrew W. Saul before the Government of Canada, House of Commons
Standing Committee on Health, regarding natural health product safety
(Ottawa, May 12, 2005).
(Andrew W. Saul has taught clinical nutrition for New York Chiropractic
College, and taught health science and biology for the State University
of New York for nine years. The author of three nutrition books, Saul
is also Contributing Editor for the Toronto-based Journal of
Orthomolecular Medicine.)
OVERVIEW
Natural health products, such as amino acids, herbs, vitamins and
other nutritional supplements, have an extraordinarily safe usage
history. In the USA, close to half of the population takes herbal or
nutritional supplements every day. That is over 145,000,000 individual
doses daily, for a total of over 53 billion doses annually.
The most elementary of forensic arguments is, where are the bodies?
To try to answer this question, we may turn to the 2003 Annual
Report of the American Association of Poison Control Centers Toxic
Exposures Surveillance System, published in the American Journal of
Emergency Medicine, Vol. 22, No. 5, September 2004.
(http://www.aapcc.org/Annual%20Reports/03report/Annual%20Report%202003.pdf)
This report states that there have been four deaths attributed to
vitamin/mineral supplements in the year 2003. Two of those deaths were
due to iron poisoning. That means there have been two deaths allegedly
caused by vitamins, out of over 53 billion doses. That is a product
safety record without equal.
Pharmaceutical drugs, on the other hand, caused over 2,000 poison control-reported deaths, including:
Antibiotics: 13 deaths
Antidepressants: 274 deaths
Antihistamines: 64 deaths
Cardiovascular drugs: 162 deaths
It would be incorrect to state that only prescription drugs kill
people. In 2003, there were 59 deaths from aspirin alone. That is a
death rate nearly thirty times higher than that of iron supplements.
Furthermore, there were still more deaths from aspirin in combination
with other products.
Fatalities are by no means limited to drug products. In the USA in
the year 2003, there was a death from "Cream/lotion/makeup," a death
from "Granular laundry detergent," one death from "Gun bluing," one
death from plain soap, one death from baking soda, and one death from
table salt.
Other deaths reported by the American Association of Poison Control Centers included:
aerosol air fresheners: 2 deaths
nailpolish remover: 2 deaths
perfume/cologne/aftershave: 2 deaths
charcoal: 3 deaths
dishwashing detergent: 3 deaths
(and interestingly, weapons of mass destruction: 0 deaths)
In America in 2003, there were 28 deaths from heroin, and yet
acetaminophen ("Tylenol") alone killed 147. Though acetaminophen killed
over five times as many, few would say that we should make this
generally-regarded-as-safe, over-the-counter pain reliever require
prescription. Even caffeine killed two people in 2003, a number equal
to the two fatalities attributed to non-iron vitamin/mineral
supplements. Tea, coffee and cola soft drinks are not sold with
restriction, prescription, or in childproof bottles, and rather few
would maintain that they need to be.
A CLOSER LOOK AT ALLEGATIONS OF VITAMIN FATALITIES
Nutritional supplements are exceptionally safe. In 2003, there were
no deaths from multiple vitamins without iron. There were no deaths
from amino acids. There were no deaths from B-complex vitamin
supplements. There were no deaths from niacin. There were no deaths
from vitamin A. There were no deaths from vitamin D. There were no
deaths from vitamin E.
There was, supposedly, one alleged death from C and one alleged death from B-6.
The accuracy of such attribution is questionable, as water-soluble
vitamins such as B-6 (pyridoxine) and vitamin C (ascorbate) have
excellent safety records stretching back for many decades. "Vitamin
problem" allegations are routinely overstated and unconfirmed. The
latest (2003) Toxic Exposures Surveillance System report indicates that
reported deaths are "probably or undoubtedly related to the exposure,"
a clear admission of uncertainty in the reporting. (p 340)
Even if true, such events are aberrations. For example, In 1998,
the American Association of Poison Control Centers' Toxic Exposure
Surveillance System reported no fatalities from either vitamin C or
from B-6. In fact, that year there were no vitamin fatalities
whatsoever. For decades I have asked my readers, colleagues, and
students to provide me with any and all scientific evidence of a
confirmed death from either of these two vitamins, or from any other
vitamin. I have seen none to date.
Even the mistakenly-believed "side effects" of vitamin C have been
found to be completely mythical. According to a National Institutes of
Health report published in the Journal of the American Medical
Association (April 21, 1999), none of the following problems are caused
by taking "too much vitamin C":
Allegations of Hypoglycemia
Allegations of Rebound scurvy
Allegations of Infertility
Allegations of Destruction of vitamin B-12
Rather than focus on infinitesimally minimal supplement risk, it is
vitamin deficiency that is the vastly more serious public health issue.
For example, B-6 (pyridoxine) supplementation should be actively
encouraged, as larger-than-food quantities of this vitamin has been
demonstrated to prevent both cardiovascular disease and depression,
diseases that are enormous public health problems. Women who use the
birth control pill experience vitamin B-6 deficiency, and need to be
encouraged to supplement with it. (Wynn, V. Lancet, March 8, 1975.)
SAFETY OF VITAMIN A AND CAROTENE
Vitamin A, as carotene or fish oil, gives you healthy mucus membranes, a strong immune system, and helps prevent cancer.
In one review of 50 years of vitamin research, researchers noted
that "approximately 10 to 15 cases of vitamin A toxic reactions are
reported per year in the United States, usually at doses greater than
100,000 IU. No adverse effects have been reported for beta-carotene (a
vitamin A precursor)." (Meyers DG, Maloley PA, Weeks D. Safety of
antioxidant vitamins. Arch Intern Med. 1996 May 13;156(9):925-35.)
After first taking note that this review confirms safety, some
explanation is necessary. First, a "toxic reaction" is very different
from a "fatality." Had their been any fatalities, the authors would
have said as much. Unfortunately, "toxic" may erroneously imply
"deadly." That is not the meaning of toxic as it properly applies here:
toxic means "makes you sick." American poison control statistics
repeatedly fail to show even one single death from vitamin A in a given
year.
Pregnancy is a special case where prolonged intake of too much
preformed oil-form vitamin A might be harmful to the fetus, even at
relatively low levels (under 25,000 IU/day). Interestingly enough, you
can get over 100,000 IU of vitamin A from eating only six ounces of
beef liver. I have yet to see a pregnancy overdose warning on a package
of liver.
It is vitamin A deficiency during pregnancy, and in infancy, that
poses the far greater risk. Deficiency of vitamin A in developing
babies is known to cause birth defects, poor tooth enamel, a weakened
immune system, and over 100,000 cases of blindness annually. Megadoses
of vitamin A are considered sufficiently safe to be given to newborns
to prevent infant deaths and disease. (Basu S, Sengupta B, Paladhi
PK.Single megadose vitamin A supplementation of Indian mothers and
morbidity in breastfed young infants. Postgrad Med J. 2003
Jul;79(933):397-402. And: Rahmathullah L, Tielsch JM, Thulasiraj RD,
Katz J, Coles C, Devi S, John R, Prakash K, Sadanand AV, Edwin N,
Kamaraj C. Impact of supplementing newborn infants with vitamin A on
early infant mortality: community based randomized trial in southern
India. BMJ. 2003 Aug 2;327(7409):254.)
SAFETY OF THE B-COMPLEX VITAMINS
The safety record of the B-complex vitamins is extraordinarily
good. Since their discovery, beginning with thiamin (B-1) in 1911, many
thousands of studies have verified an unequaled therapeutic value of
these essential substances. Side effects have been rare, and toxicity
is nearly nonexistent, even at the highest doses.
B-1, B-2, B-12, Biotin, Folate, Pantothenic Acid
Regulating blood sugar, nourishing your nerves, improving mood, and
preventing cardiovascular disease are just a few reasons people take
the B-complex vitamins. They are cheap and safe. Both the 1998 and 2003
American Association of Poison Control Centers' Toxic Exposure
Surveillance System report shows no deaths whatsoever from Thiamin
(B-1), Riboflavin (B-2), Cobalamin (B-12), Biotin, Folate or
Pantothenic Acid. Furthermore, there are no toxicity reports published
for these vitamins in the Merck Manual, generally regarded as a
particularly authoritative medical reference.
Vitamin B-3 (Niacin; Niacinamide, Inositol Hexaniacinate)
For over 50 years, nutritional (orthomolecular) psychiatrists have
used niacin (vitamin B-3) in doses as high as tens of thousands of
milligrams per day. It is an effective treatment for obsessive
compulsive disorder, anxiety, bipolar disorder, depression, psychotic
behavior, and schizophrenia. Niacin has also gained popularity as one
of the cheapest and safest ways to lower cholesterol.
The discoverer of niacin therapy for lowering cholesterol, Canadian
psychiatrist Abram Hoffer, M.D., says that niacin is very safe. "There
have been no deaths from niacin supplements," Dr. Hoffer says. "The LD
50 (the dosage that would kill half of those taking it) for dogs is
5,000-6,000 milligrams per kilogram body weight. That is equivalent to
almost a pound of niacin per day for a human. No human takes 375,000
milligrams of niacin a day. They would be nauseous long before reaching
a harmful dose. The top niacin dose ever was a 16-year-old
schizophrenic girl who took 120 tablets (500 mg each) in one day. All
that happened was that the 'voices' she was hearing stopped."
Physicians frequently give patients 2,000–5,000 mg of niacin daily
to lower cholesterol. The safety margin is very large. The 2003
American Association of Poison Control Centers' Toxic Exposure
Surveillance System report indicates no deaths whatsoever from niacin.
Vitamin B-6
Vitamin B-6 (pyridoxine) improves mood, reduces risk of
cardiovascular disease, and has been shown to be clinically effective
against carpal tunnel syndrome. It also has been occasionally reported
to cause temporary neurological symptoms such as heaviness, tingling,
or numbness of the limbs in persons taking very large doses. It is very
important to realize that such cases are not common, and when they do
occur almost always result from huge doses of pyridoxine taken alone.
B-6 by itself in doses of 2,000 to 6,000 mg daily (that is 1,200 to
3,600 times the standard U.S. dietary recommendation) can produce side
effects. Very few persons report symptoms on 1,000 mg daily (600 times
the US RDA), and only the rarest reports go any lower. When taken with,
or as part of, a complete B-complex supplement, B-6 side effects are
virtually unknown.
Premenstrual tension symptoms often improve dramatically with only
a few hundred mg/day of extra B-6 taken in divided doses throughout the
day. At least 50 to 100 mg of supplemental B-6 daily is a virtual
necessity for women taking oral contraceptives. The "pill" causes some
abnormal physiological changes that create a deficiency of B-6, as well
as lower serum levels of thiamine (B-1), riboflavin (B-2), niacin
(B-3), folic acid, B-12, and vitamin C.
VITAMIN C
The importance of vitamin C cannot be overemphasized. Vitamin C has
been shown to be helpful in fighting over thirty major diseases,
including pneumonia, herpes zoster (shingles), pancreatitis, hepatitis,
arthritis, some forms of cancer, leukemia, atherosclerosis, high
cholesterol, diabetes, multiple sclerosis, and chronic fatigue.
(Vitamin C, Infectious Diseases, and Toxins: Curing the Incurable, by
Thomas E. Levy, M.D. Philadelphia: Xlibris Corporation, 2002.)
Many well designed studies show that large doses of vitamin C
improve both quality and length of life for cancer patients. (Murata,
A., Morishige, F. and Yamaguchi, H. Prolongation of survival times of
terminal cancer patients by administration of large doses of ascorbate.
International Journal of Vitamin and Nutrition Research Suppl., 23,
1982, p. 103-113. And: Null, G., Robins, H., Tanenbaum, M., and
Jennings, P. Vitamin C and the treatment of cancer: abstracts and
commentary from the scientific literature. The Townsend Letter for
Doctors and Patients. April/May, 1997. And: Riordan, N. H., et al.
Intravenous ascorbate as a tumor cytotoxic chemotherapeutic agent.
Medical Hypotheses, 44(3). p 207-213, March 1995.)
"Vitamin C," wrote board-certified chest physician Frederick R.
Klenner, M.D., "is one of the safest substances you can put in the
human body." Vitamin C is remarkably safe even in enormously high
doses. Compared to commonly used prescription drugs, side effects are
virtually nonexistent. It does not cause kidney stones. In fact,
vitamin C increases urine flow, favorably lowers urine pH, and prevents
calcium from binding with urinary oxalate. All these features help keep
stones from forming. (Gerster H. No contribution of ascorbic acid to
renal calcium oxalate stones. Ann Nutr Metab. 1997;41(5):269-82. "In
the large-scale Harvard Prospective Health Professional Follow-Up
Study, those groups in the highest quintile of vitamin C intake (>
1,500 mg/day) had a lower risk of kidney stones than the groups in the
lowest quintiles.")
It was Canadian physician William J. McCormick, M.D., who first
advocated vitamin C to prevent and cure the formation of kidney stones
50 years ago (McCormick, WJ. Lithogenesis and hypovitaminosis. Medical
Record. 159:7, July, p 410-413). In 1946 he wrote:
"I have observed that a cloudy urine, heavy with phosphates and
epithelium, is generally associated with a low vitamin C status. . .
and that as soon as corrective administration of the vitamin effects a
normal ascorbic acid (vitamin C) level the crystalline and organic
sediment disappears like magic from the urine. I have found that this
change can usually be brought about in a matter of hours by large doses
of the vitamin, 500 to 2,000 mg, oral or parenteral." (p. 411) [Journal
of Orthomolecular Medicine, Vol. 18, No. 2, 2003, p 93-96.]
Even a modest quantity of supplemental vitamin C prevents disease
and saves lives. Just 500 mg daily results in a 42 percent lower risk
of death from heart disease and a 35 percent lower risk of death from
any cause. (Enstrom J.E., Kanim L.E., and Klein M.A. Vitamin C intake
and mortality among a sample of the United States population.
Epidemiology 3 (1992):194–202.) Since at least two-thirds of the
population is not eating sufficient fruits and vegetables, the only way
to close the gap is with vitamin supplements.
VITAMIN D
Canadian researcher Reinhold Vieth, Ph.D., writes, "Published cases
of vitamin D toxicity with hypercalcemia, for which the 25(OH)D
concentration and vitamin D dose are known, all involve intake of
greater than or equal to 1,000 micrograms (40,000 IU)/day. (T)he weight
of evidence shows that the currently accepted, no observed adverse
effect limit of 50 microg (2,000 IU)/d is too low by at least 5-fold."
(Vieth R. Vitamin D supplementation, 25-hydroxyvitamin D
concentrations, and safety. Am J Clin Nutr. May; 69(5):842-56. 1999.)
The Nutrition Desk Reference, Second Edition states that, for vitamin
D, "The threshold for toxicity is 500 to 600 micrograms per kilogram
body weight per day." (p 40) The US Environmental Protection Agency's
published oral LD50 for female rats of 619 mg/kg (Cholecalciferol
(Vitamin D3) Chemical Profile 12/84. US Environmental Protection
Agency, Washington, DC. Chemical Fact Sheet Number 42. December 1,
1984.)
500 to 600 mcg is the equivalent of 20,000 to 24,000 IU, per kilogram
body weight per day. By comparison, this would mean that for an average
(70 kg) adult human, toxicity would occur at an astounding 1,400,000 to
1,680,000 IU/day.
Yet misconceptions and misinformation about vitamins persist.
Vitamin-scare articles are unduly popular with the media, sometimes
even making it into the pages of the Wall Street Journal. On April 30,
1992, David Stipp reported that between 1990 and 1992, "a series of
patients with vitamin D overdoses began turning up at Boston
hospitals." Due to problems at one large dairy, some of the milk sold
in Boston contained over 230,000 units of vitamin D per quart instead
of the usual 400 units per quart.
One person subsequently died from drug complications, and the case
went to court. (Tarpey v. Crescent Ridge Dairy, Inc., 47 Mass. App. Ct.
380.) "Essentially, this was a product liability action against the
producer of dairy products, specifically milk which contained excessive
amounts of Vitamin D. The plaintiff's decedent purportedly suffered
from elevated levels of Vitamin D in her bloodstream which required
medication which in turn allegedly compromised her immune system,
leading to her death."
(http://www.dwpm.com/content/main/litigation00_news.php3)
This is the one and the only vitamin D-related death I could find
confirmation of, ever, anywhere. And even this one was not directly due
to the vitamin, but rather to side effects of medication.
The incident might well be taken as an unintentional proof of
vitamin safety, even in ridiculously high overdosage situations. It is
certainly noteworthy that 580 times the normal amount of vitamin D
produced, at most, one alleged fatality. This borders on the
extraordinary. Events such as this demonstrate that the margin for
error with vitamins is very large indeed.
As a former university nutrition instructor, the classroom
textbooks I taught with considered vitamin D to be perhaps the most
potentially dangerous vitamin to chronically overdose on. If that is
true, and there has been not even one confirmed vitamin-D fatality in
the USA in over forty years, then all other vitamins are safer still.
(Journal of Orthomolecular Medicine, 2003; Vol. 18, Numbers 3 and 4, p.
194-204.)
VITAMIN E
Poison control statistics report no deaths from vitamin E. Vitamin
E is a safe and remarkably non-toxic substance. Canadian cardiologists
Drs. Wilfrid and Evan Shute observed no evidence of harm with doses as
high as 8,000 IU/day. In fact, "toxicity symptoms have not been
reported even at intakes of 800 IU per kilogram of body weight daily
for 5 months," according to the US Food and Nutrition Board. This
demonstrated safe level would work out to be around 60,000 IU daily for
an average adult, some 2,700 times the US RDA.
A Columbia University study reported progression of Alzheimer's
disease was significantly slowed in patients taking high daily doses
(2,000 IU) of vitamin E for two years. The vitamin worked better than
the drug selegiline did. The patients in the Alzheimer's study
tolerated their vitamin E doses well. Perhaps the real story is that
2,000 IU per day for two years is safe for the elderly.
Overexposure to oxygen has been a major cause of retrolental
fibroplasia (retinopathy of prematurity) and subsequent blindness in
premature infants. Incubator oxygen retina damage is now prevented by
giving preemies 100 mg E per kilogram body weight. That dose is
equivalent to an adult dose of about 7,000 IU for an average-weight
adult. "There have been no detrimental side effects" from such
treatment, said the New England Journal of Medicine. (Hittner HM, Godio
LB, Rudolph AJ, Adams JM, Garcia-Prats JA, Friedman Z, Kautz JA, Monaco
WA. Retrolental fibroplasia: efficacy of vitamin E in a double-blind
clinical study of preterm infants. N Engl J Med. 1981 Dec 3;
305(23):1365-71.)
Regular supplementation with vitamin E is likely to save literally
millions of lives. The New England Journal of Medicine published two
papers in the May 20, 1993 issue showing that persons taking vitamin E
supplements had an approximately 40% reduction in cardiovascular
disease. Nearly 40,000 men and 87,000 women took part in the studies.
The more vitamin E they took, and the longer they took it, the less
cardiovascular disease they experienced.
A 1996 double-blind, placebo-controlled study of 2,002 patients
with clogged arteries demonstrated a 77% decreased risk of heart attack
in those taking 400 to 800 IU of vitamin E. (Stephens, NG et al.
Randomized controlled trial of vitamin E in patients with coronary
artery disease: Cambridge Heart Antioxidant Study (CHAOS)," Lancet,
March 23, 1996; 347:781-786.)
Such effective quantities of vitamin E positively cannot be obtained
from diet alone. 800 IU is 2,667% of the US DRI for vitamin E. (Journal
of Orthomolecular Medicine, Volume 17, Number 3, Third Quarter, 2002 (p
179-181) And: Journal of Orthomolecular Medicine, 2003; Vol. 18,
Numbers 3 and 4, p. 205-212.)
HERBAL SUPPLEMENTS
The 2003 Report of the American Association of Poison Control
Centers Toxic Exposures Surveillance System
(http://www.aapcc.org/Annual%20Reports/03report/Annual%20Report%202003.pdf)
indicates a total of 13 deaths attributed to herbal preparations. Three
of these are from ephedra, two from yohimbe, and two from ma-huang. I
have worked extensively in the alternative health field for nearly 30
years, and I have known of virtually no one who has taken ephedra,
yohimbe, or ma-huang, and certainly not in the deliberately abusive
high quantities that it takes to kill someone. Nevertheless, accepting
all seven deaths attributed to these products, we still find that there
were 30 times as many deaths from aspirin and acetaminophen.
Only three deaths are attributable to other "single ingredient
botanicals," and oddly enough, their identity remains unnamed in the
Toxic Exposures report.
Millions of persons take herbal remedies, and have done so for
generations. Indigenous and Westernized peoples alike have found them
to be safe and effective, and the 2003 Report of the American
Association of Poison Control Centers Toxic Exposures Surveillance
System confirms this (p 388-389). There have been no deaths at all from
"cultural medicines," including ayurvedic, Asian, Hispanic, and in
fact, from all others.
Additionally, we find:
Blue cohosh: 0 deaths
Ginko biloba: 0 deaths
Echinacea: 0 deaths
Ginseng: 0 deaths
Kava kava: 0 deaths
St John's wort: 0 deaths
Valerian: 0 deaths
Furthermore, there have been no deaths from phytoestrogens, glandulars, blue-green algae, or homeopathic remedies.
MINERAL SUPPLEMENTS
Of the eight deaths in the category, five of them are from
non-supplement sources rightly termed "electrolytes": two from sodium
and three from potassium (p 389). Two deaths were allegedly due to iron
overdose. Since 1986, there has been an average of two deaths per year
"associated with" iron supplements. The sole remaining death was from
calcium, a mineral that is employed medically for its antidote
properties. In fact, in 2003, calcium was used as a lifesaving antidote
in 5,228 cases (p 344). There is no evidence that the single listed
calcium death was from a supplement, and the odds are overwhelming that
it was not.
AMINO ACID SUPPLEMENTS
In 2003, poison control centers reported no deaths whatsoever from amino acids. This is in itself a strong safety statement.
IN PERSPECTIVE
Supplementation's harshest critics have traditionally railed
against vitamins (especially in large doses) as being outright
"dangerous" and at the very least "a waste of money." Yet nutritional
supplements are very safe, and for much of the population, very
necessary. The Journal of the American Medical Association has recently
published the recommendation that every person take a multivitamin
daily (Fletcher RH and Fairfield KM. Vitamins for Chronic Disease
Prevention in Adults: Clinical Applications JAMA. 2002; 287:3127-3129.
And: Fairfield KM and Fletcher RH. Vitamins for Chronic Disease
Prevention in Adults: Scientific Review. JAMA. 2002; 287:3116-3126.)
saying that "(S)uboptimal intake of some vitamins, above levels causing
classic vitamin deficiency, is a risk factor for chronic diseases and
common in the general population, especially the elderly." Therefore,
JAMA's intent goes beyond routine nutritional insurance for widespread
bad-to-borderline diets. The goal is stated in the article's title:
"Vitamins for chronic disease prevention in adults." It is a sensible
idea whose time should have come generations ago.
To illustrate how extraordinarily important supplements are to
persons with a questionable diet, consider this: Children who eat hot
dogs once a week double their risk of a brain tumor. Kids eating more
than twelve hot dogs a month (that's barely three hot dogs a week) have
nearly ten times the risk of leukemia as children who ate none. (Peters
JM, Preston-Martin S, London SJ, Bowman JD, Buckley JD, Thomas DC.
Processed meats and risk of childhood leukemia. Cancer Causes Control.
1994 Mar; 5(2):195-202.)
However, hot-dog eating children taking supplemental vitamins were
shown to have a reduced risk of cancer. (Sarasua S, Savitz DA. Cured
and broiled meat consumption in relation to childhood cancer. Cancer
Causes Control. 1994 Mar; 5(2):141-8.)
It is curious that, while theorizing many "potential" dangers of
vitamins, the media often choose to ignore the very real
cancer-prevention benefits of supplementation.
Critics also fail to point out how economical supplements are. For
low-income households, taking a two-cent vitamin C tablet and a
five-cent multivitamin, readily obtainable from any discount store, is
vastly cheaper than getting those vitamins by eating right. The
uncomfortable truth is that it is often less expensive to supplement
than to buy nutritious food, especially out-of-season fresh produce.
According to David DeRose, M.D., M.P.H., "300,000 Americans die
annually from poor nutrition choices." Supplements make any dietary
lifestyle, whether good or bad, significantly better. Supplements are
an easy, practical entry-level better-nutrition solution for the
public. A television-educated populace is more likely to take some
tablets than to willingly eat organ meats, wheat germ, bean sprouts and
ample vegetables. Media supplement-scare-stories notwithstanding,
taking supplements is not the problem; it is a solution. Malnutrition
is the problem. (Journal of Orthomolecular Medicine, 2003; Vol. 18,
Numbers 3 and 4, p. 213-216.)
PUBLIC SUPPORT FOR FREE ACCESS TO NUTRITIONAL SUPPLEMENTS
A recent (March 26, 2003) and unsuccessful American attempt to
restrict free public access to vitamin supplements was U.S. Senate Bill
S. 722, the so-called "Dietary Supplement Safety Act of 2003." The
proposed law attempted to give the Secretary of the US Food and Drug
Administration sole power decide if and when "the continued marketing
of the dietary supplement is disapproved" (2-B: ii) based on adverse
event reporting so vague that the proposed bill specified that decision
was "without regard to whether the event is known to be causally
related to the dietary supplement." (SEC. 416 (a)(1)
The intent of S. 722 was to overturn the main provisions of the
U.S. Dietary Supplement Health and Education Act of 1994 (DSHEA). The
US Congress enacted DSHEA specifically to define vitamins, amino acids,
herbs, and other nutritional supplements as foods, not drugs. DSHEA
enjoyed tremendous popular support. More citizen letters were sent to
Congress in 1992-1994 in favor of DSHEA than over any other issue in
American history. Some 2.5 million individual voters' letters were
received by US Senators and Representatives. On the other hand, citizen
opposition to S. 722 was strong. It gathered only four cosponsors, and
failed in committee.
The U.S. Congress has clearly seen that there is overwhelming public
support for ensuring free access to dietary supplements. I believe
Canadians have the same keen interest, and that an affirmative vote on
Canada's proposed legislation, C-420, to rightly consider supplements
as foods and not drugs, will be well-received by the citizens of
Canada.
CONCLUSION:
As it has been for thousands of years of human history, so the
malnutrition problem remains with us today. Only in the last century
have supplements even been available. Their continued use represents a
true public health breakthrough on a par with clean drinking water and
sanitary sewers, and can be expected to save as many lives.
The number one side effect of vitamins is failure to take enough of
them. Vitamins are extraordinarily safe substances. Drugs are not.
There are over 106,000 deaths from pharmaceutical drugs each year in
the USA, even when prescribed correctly and taken as prescribed.
(Lucian Leape, Error in medicine. Journal of the American Medical
Association, 1994, 272:23, p 1851. Also: Leape LL. Institute of
Medicine medical error figures are not exaggerated. JAMA. 2000 Jul
5;284(1):95-7.)
Public supplementation should be encouraged, not discouraged.
Supplements are a cost-effective means of preventing and ameliorating
illness. Supplement safety is outstandingly high. Natural health
products should be classified as foods, not drugs.
(end of testimony)
Andrew Saul is the author of the books FIRE YOUR DOCTOR! How to be Independently Healthy (reader reviews at http://www.doctoryourself.com/review.html ) and DOCTOR YOURSELF: Natural Healing that Works. (reviewed at http://www.doctoryourself.com/saulbooks.html )
"A lot of people go through life trying to prove that the things
that are good for them are wrong." (Ward Cleaver, on "Leave it to
Beaver")
"There is a principle which is a bar against all information, which
is proof against all argument, and which cannot fail to keep man in
everlasting ignorance. That principle is condemnation without
investigation." (Herbert Spencer)
Thanks to George D Henderson for finding this information.
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