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To: CODEX DELEGATES FROM ALL MEMBER COUNTRIES PARTICIPATING IN THE CODEX COMMITTEE ON NUTRITION AND FOODS FOR SPECIAL DIETARY USES- BONN, GERMANY ON NOVEMBER 1-5: "NO" to FINALIZING AGENDA ITEM #4- THE STANDARD FOR VITAMINS AND MINERALS As a vitamin consumer concerned about safeguarding the public health, I totally oppose finalization of AGENDA ITEM # 4 (VITAMINS AND MINERALS) at step 8, and urge you to vote against such finalization due to the specific public health concerns expressed by the Alliance for Natural Health; Alan Gaby, MD; Gladys Block,PhD; Alan Dobson, PhD; Gary Null,PhD,Carolyn; Dean,MD,ND,Cheraskin, MD and Ringsdorf Jr,MD cited below. OPPOSE GERMAN PROPOSAL TO INCORPORATE SO CALLED "POSITIVE LIST" OF "ADMISSIBLE VITAMINS" INTO CODEX FROM EU FOOD SUPPLEMENT DIRECTIVE ESPECIALLY Oppose finalization IF the vitamin and mineral standard contains Germany's proposal to incorporate an Appendix which would create a (so-called) "Positive List" of "admissible" vitamins and minerals (similar to that found in EU Directive 2002/46/EC). (Germany made this recommendation in their written comments submitted before the 2003 CCNFSDU Meeting- see Section 3.1.2 and 3.2.2 in Germany's comments http://www.codexalimentarius.net/web/archives.jsp?lang=EN Meeting of the CCNFSDU 2003 EUROPEAN FOOD SUPPLEMENT DIRECTIVE (AND THIS SO CALLED "POSITIVE LIST") IS BEING CHALLENGED IN THE EUROPEAN COURT OF JUSTICE This "positive list" of "admissible" vitamins and minerals is being challenged in the European Court of Justice by the Alliance for Natural Health, a pan European group of concerned dietary supplement consumers, manufacturers, and alternative practitioners who have widespread international support for their work http://www.alliance-naturalhealth.org , ANH has received a referral to ECJ court by the High Court in London, they've filed papers with the ECJ and are awaiting a court date. They fully intend to overturn EU Directive 2002/46/EC on the grounds that it violates European law by arbitrarily, and without any scientific justification, blocks the sale of nearly 300 safe ingredients which have been in use in dietary supplements for DECADES in Britain and around the world. They contend that the European Food Supplement Directive is supposed to EXPAND the sale of dietary supplements, when in reality, the so called "Positive" list actually has the OPPOSITE effect--- of arbitrarily and capriciously REDUCING the number, kinds, and potencies of products ALLOWED to be sold, and wholly without just cause based on sound science. It is apparent to me that if the German Chair of the CCNFSDU meeting pushes for and allows this EU based "Positive List" to be incorporated into a global trade standard, that their motives would have NOTHING to do with safeguarding the public health, and EVERYTHING to do with protecting Germany's huge pharmaceutical industry from unwanted competition from safe dietary supplements. If the CCNFSDU finalizes a standard for vitamins and minerals DESPITE our concerns, millions of vitamin consumers world wide would be forced to regard the UN as having an EUGENICS agenda that is RADICALLY INCONSISTENT with any expressed desire to "safeguard the public health" This would bring the UN into serious disrepute with vitamin consumers and others around the world. It would be PREMATURE to advance a global trade standard for vitamins and minerals based on the European Food Supplement Directive while the Alliance for Natural Health's court case is still pending. GABY: SAFE UPPER LEVELS FOR NUTRITIONAL SUPPLEMENTS: ONE GIANT STEP BACKWARD Furthermore, the move to create a framework intended to eventually cap allowable potency levels for vitamins and minerals based on so called "Safe Upper Levels" is not the least bit scientific and must be REJECTED!! We call your attention to this article SAFE UPPER LEVELS FOR DIETARY SUPPLEMENTS: ONE GIANT STEP BACKWARD by Alan Gaby, MD which was published in a Special Issue of the Journal of Orthomolecular Medicine Volume 18 Third & Fourth Quarters, 2003 Numbers 3 & 4 devoted to the safety and efficacy of dietary supplements http://www.iahf.com/20040127.html Gaby, a highly experienced clinician with years of experience in treating patients using dietary supplements, is sharply critical of the UK's "Expert Group on Vitamins and Minerals" report to the Food Standard Agency that set "Safe Upper Levels" for the doses of most vitamins and minerals. Gaby notes that the EVM Report reveals "that the dose levels were set inappropriately low for many vitamins and minerals; well below doses which have been used by the public for decades with apparent safety." Gaby states that the public health could be jeopardized if this report is used as the basis for creating public policy. Gaby is sharply critical of guidance levels created for Riboflavin, B6, Manganese, Niacin and Vitamin C, noting that benefits were ignored, while only risks were focused on- and that this is not science. "While the directive to evaluate only the risks, and to ignore the benefits, of nutritional supplements created a rigged game, the members of the EVM appeared to be willing participants in that game." GLADYS BLOCK, PhD CONDEMNS RDAs AS UNSCIENTIFIC, CALLS FOR OPTIMAL NUTRIENT LEVELS TO SAFEGUARD PUBLIC HEALTH Comments made by Gladys Block, PhD ( http://sph.berkeley.edu:7133/faculty/block.htm ) at the US National Academy of Sciences symposium on RDAs held June 28-29, 1993 are in sync with Gaby's concerns. (Food Chemical News- July 5, 1993) Block agreed that RDAs should address "Optimal" levels of nutrients needed to prevent chronic diseases. "The RDAs are meaningless and pointless if they don't bear a relation to health," declared Dr.Gladys Block, University of California (Berkley) School of Public Health, noting that the public already believes the recommended levels are "adequate to keep us in reasonably good health so we won't die prematurely." Explaining why the NAS Food and Nutrition Board had not addressed chronic diseases in the past, Block cited poor or inappropriate methods for determining optimal intake, and a focus on short-term "unifactorial" outcomes such as beriberi or scurvy. For example, the RDA for vitamin E is based on levels of intake by "apparently healthy people" despite evidence that higher levels could reduce risk for atherosclerosis, cancer, and cataracts, she said. Describing humans as "living in a sea of oxidative agents and free radicals" that lead to chronic diseases, Block charged that the current RDA's are sufficient "to get us through our reproductive years," after which nature ceases to care what happens to our bodies. "Calling the RDA's adequate for long term health is incorrect," she declared. Asserting that knowledge of nutrient needs is "exploding," Block urged scientists to "look for intersections between epidemiology and biochemistry" in trying to arrive at appropriate nutrition recommendations. She continued: "We should err on the side of public health. The burden of proof should lie with those who say less is adequate rather than those who say more is beneficial." Block noted that chronic diseases affect very large population segments and account for billions of dollars in health care costs. "I'm convinced that substantially higher intake of antioxidants would decrease the risk of diseases of maturity and old age," she concluded. Asked about possible harm to vulnerable sub populations from higher nutrient intakes, Block conceded some risks due to genetic variability. "However I'm reassured because a majority benefit," she continued, adding "Its like pesticide residues on fruits and vegetables. Sure, its a worry, but people with high levels of antioxidants have a lower risk of cancer." ADDITIONAL EVIDENCE THAT CODEX GOES AGAINST SOUND SCIENCE- STATEMENT BY AL DOBSON,PhD, The Lewin Group, Falls Church,Virginia- Statement Before the Committee on Government Reform, US House of Representatives- REGARDING: Dietary Supplements: Nature's Answer to Cost Effective Preventative Medicine Date: September 22, 2004 http://reform.house.gov/UploadedFiles/testimony%20dobson.pdf At the Codex Committee on Food Labeling in Montreal, South Africa introduced a proposal that would have allowed for the making of truthful health claims for dietary supplements, citing an overwhelming body of evidence attesting to the fact that these natural substances can be used to prevent disease and that this does not "make them drugs." Their proposal to change the Preamble was wrongly voted down. If finalized at Step 8, the Codex Vitamin Standard would block consumer access to healing nutrients necessary to prevent disease, and to cut down on expensive health care costs. To ignore the findings of the Lewin Group that a daily intake of 1200 mgs of calcium with vitamin D could result in 734,000 fewer hip fractures among the population age 65- and over, which could save an estimated $13.9 Billion over a 5 year period (in the USA alone) would be cast the UN's Codex Commission into serious global disrepute. Ditto to ignoring the Lewin Group's finding that at least 600 fewer children would be born with crippling neural tube defects, resulting in a lifetime savings of over $321.9 million, if just 25% of the woman of childbearing age in the US currently not taking 400 mcg of folic acid supplements began taking it. The estimated 5 year savings, taking into account the very low cost of the supplement is $1.3 Billion in lifetime costs compared with costs of caring for babies with neural tube defects. See the url above for more information. COMPREHENSIVE NUTRIENT REVIEW http://www.garynull.com/Article.aspx?Article=/documents/Codex/CodexIntro.htm A comprehensive review of 50 selected nutrients in preventing, retarding, and treating disease culled from 484,000 peer reviewed studies contained in the medical literature which justify the use of OPTIMAL doses of vitamins, minerals, and other natural substances. Null, et al generated this paper due to CONCERN about the effort underway at Codex to create a global trade standard for vitamins and minerals that goes against the public health. If the UN ignores this paper, and passes a finalized Codex Vitamin Standard over all these objections, it will fall into serious global disrepute and we'd only be able to conclude that it has a Eugenics Agenda. SUGGESTED OPTIMAL NUTRIENT ALLOWANCE Through the effort of a 15 year study it is now possible to extrapolate suggested optimum daily nutrients allowances, or SONA's. These SONA's are levels of nutrients found in a study of 13,500 male and female subjects living in six regions of the United States conducted by senior investigators, Drs. Emanuel Cheraskin and W. M. Ringsdorf Jr. of the University of Alabama School of Medicine. The results of their two million dollar study are contained in 49,000 bound pages found in 153 volumes, whose results have been published in over 100 papers during the 1970's and 1980's. http://www.enerex.ca/chinese/Establishing%20SONA.htm ANH's, Gaby's, Block's, Dobson's, Null and Dean's, Cheraskin and Ringsdorf Jr's concerns reflect my own that the proposed Codex vitamin standard threatens the public health. Sound Science and respect for the Public Health require that all work on creating a global trade standard for vitamins and minerals immediately CEASE, or at the VERY LEAST be set back to step 3 so that PROPER CONSIDERATION of these concerns be given MORE TIME to be PROPERLY ADDRESSED. Information Courtesy Of John C. Hammell, President, International Advocates for Health Freedom http://www.iahf.com 556 Boundary Bay Rd., Point Roberts, WA 98281 USA 800-333-2553 N.America 360-945-0352 World