CODEX ALIMENTARIUS

From a good friend of mine, hope you all will find it as interesting as i did...*PLEASE SHARE.*

To Whom it may concern,

In reference to the BBC article, 'British GM crop scientists win $10m grant from Gates'

(able to read here - http://www.bbc.co.uk/news/science-environment-18845282)

... As well as the a follow up article by Tom Fileden, Time for a re-think on GM crops?

(able to read here - http://www.bbc.co.uk/news/science-environment-18593639)

The first article is pure propaganda by the best in the world, the BBC. With out an authors name, it pushes the idea of GM usage into the readers consciousness using the most lowest form of bias reporting, implementing the victim consciousness of the poor of Africa.

'A team of British plant scientists has won a $10m (£6.4m) grant from the Gates Foundation to develop GM cereal crops.
It is one of the largest single investments into GM in the UK and will be used to cultivate corn, wheat and rice that need little or no fertiliser.
It comes at a time when bio-tech researchers are trying to allay public fears over genetic modification.
The work at the John Innes Centre in Norwich is hoped to benefit African farmers who cannot afford fertiliser.'

The Gates Foundation is backed by Bill Gates (http://en.wikipedia.org/wiki/Bill_%26_Melinda_Gates_Foundation) who is a big advocate of eugenic programmes, with shares in Monsanto (the high controversial pharmaceutical giant, that acts more like a drug dealing mafia cartel). None of these possible facts are presented in the news article, I had to do the research myself to find the hidden agenda. (http://www.naturalnews.com/035105_Bill_Gates_Monsanto_eugenics.html)

Euro' MP's, journalists and most of the public now are wrapped around their little fingers on the subject of GM products, which at this level of messing with nature is like playing with a loaded revolver. The BBC seems very in favour of this programme with almost no perspective of the real dangers of GMO food products.

Little is rarely known about the fact that ALL ORGANIC FOODS & SUPPLEMENTS now require a license to be sold, making it more and more difficult to stay organic, thanks to the CODEX ALIMNETARIUS agenda (http://video.google.com/videoplay?docid=-5266884912495233634), that no one saw coming. Its as if someone does not want us to eat organic foods anymore with less and less option, and now with the article from Tom Fielden (Time to rethink on GM crops), who seems whole heartily backing the idea that agriculture needs to be biotechnical because China and Brazil have chosen this path: he feels its the only way to solve the issue of global food security?....come on man!!!

This is not the better option for a healthy populous. In fact nothing is written about health issues,...its as if Tom is talking about something other than the food he intends to put in his mouth and digest in his stomach? I would love to see those that advocate the GMO foods, feed their own children with the stuff,...??? I know for a fact that Tom, Mr Bill Gates and all their families are eating good natural organic food, because they can afford it with the hand outs and profits they are making from backing such a business.

The truth has never really ever been reported on, just very clever NLP techniques used ( like : "Britain has a strong pedigree in agricultural research, including biotechnology, the report claims"...which plays on the national pride consciousness).

The sooner we actually get back to producing the food for ourselves once again, the more empowered we will be, feeding ourselves and producing a natural world for our children, who will be less sick with all the cheap biotechnology in foods which is more related to autism and ADT or even cancers in some cases.

If you are looking for real solutions, its not going to make our CEO's rich or raise the shareholder stakes in a company. Its going to take the people to wake up out of this illusion that the BBC, CNN and ITN ...etc, are all pushing an agenda that comes from a corporation mind set. The source to the problem is a much bigger discussion and has to do more with the addictive consumer generations we are producing today in the more developed worlds.

Learning to actually produce our own foods will always be the answer, and at some point we will have to face it. Everything else is like pouring perfume on a pig, in the end the pig will still stink.

Here are the solutions in a 5 minute video....Establishing a food forest. (also able to watch below on my time line)
http://www.youtube.com/watch?v=QVo2bOIN_AA&feature=relmfu

Feel free to post this to everyone you feel could have a responsibility in making this happen, and not falling for the false claims and false reports from Tom Fielden,

May all our thoughts and actions consider the next 7 generations....

Seven generation sustainability is an ecological concept that urges the current generation of humans to live sustainably and work for the benefit of the seventh generation into the future. It originated with the Iroquois - Great Law of the Iroquois - which holds appropriate to think seven generations ahead (a couple hundred years into the future) and decide whether the decisions they make today would benefit their children seven generations into the future.

Many thanks....http://www.bbc.co.uk/news/science-environment-18845282

PEOPLE, WEVE THE RIGHT TO EAT WHAT WE LIKE, ORGANIC FOOD IS BEST,

THESE PEOPLE HAVE NO RIGHT TO DO THIS, THEY'RE NOT ONLY TAKING AWAY

OUR FREEDOM BUT OUR RIGHTS TO CONSUME WHAT KEEPS US HEALTHY

(IF THEY DONT SUPPLY IT)...

WAKE UP SHEEPLE WAKE THE FUCK UP WE ARE BEING TAKEN OVER,

CONSUMED BY THE GOVERNMENT, THEIR BULLSHIT & RESTRICTIONS...!!!!

Citizens Confront Police Over Organic Food Raid

Aaron Dykes
Infowars.com
August 3, 2011

Footage has emerged from the raid today on Rawesome Foods in California which includes crowds of citizens spontaneously gathered to question the seizure of cash money, raw milk and even produce like mangos. Black-is-white in a new world where retailers of healthy raw milk and other foods have been arrested and held on bond at $120,000 or higher, front-yard gardeners are threatened with 90+ days in jail, but GMO kingpins can get instant safety approval and force their products on the market via close government ties. Further protest of these raids is planned for tomorrow.

As Natural News earlier reported, multiple organic stores were raided as three were arrested and charged with ‘conspiracy’. The busts, conducted as if a terrorist or druglord were inside, included multiple federal agencies, including the FDA and CDC, as well as various local agencies including LAPD, health department officials, the L.A. County Dept. of Agriculture and others.

CODEX ALIMENTARIUS –

THE SILENT STALKER OF YOUR HEALTH FREEDOM

NEVER HEARD OF CODEX? THAT'S EXACTLY WHAT THEY WANT

Ian Crane talks about the Codex Alimentarius threat and the big pharmaceutical industry.

• The world's oldest health-freedom organization

• The only one with a seat at the Codex Table

• International, with members in 20 countries

• Working hard to protect your health rights

(Fight S.510 now)

CODEX AGENDA: Only low-potency, “me too” supplements available

that will do nothing for your health

All or most foods genetically-modified and no way to know

Beneficial supplements unavailable or sold by prescription only

All Coming to You in the Future, if Codex Has its Way

Senate Bill S510 Makes it illegal to Grow, Share,

Trade or Sell Homegrown Food

"If people let the government decide what foods they eat and what medicines they take, their bodies will soon be in as sorry a state as are the souls of those who live under tyranny." ~Thomas Jefferson

According to Foodforfreedom

S 510, the Food Safety Modernization Act, may be the most dangerous bill in the history of the US

1. It puts all US food and all US farms under Homeland Security and the Department of Defense, in the event of contamination or an ill-defined emergency

2. It would end US sovereignty over its own food supply by insisting on compliance with the WTO, thus threatening national security.

3. It would remove the right to clean, store and thus own seed in the US, putting control of seeds in the hands of Monsanto and other multinationals, threatening US security

4. It deconstructs what is left of the American economy. It takes agriculture and food, which are the cornerstone of all economies, out of the hands of the citizenry, and puts them under the total control of multinational corporations

Senate Bill S510 Makes it illegal to Grow, Share, Trade or Sell Homegrown Food
http://www.infowars.com/senate-bill-s...

Since the story first broke, a lot has happened. One reason for this could be that food is being poisoned. Collecting rainwater is now illegal in many states. Your intake is being controlled. For more information, visit the following articles as well:
http://www.firetown.com/blog/2010/08/...

S 510 is hissing in the grass
http://foodfreedom.wordpress.com/2010...

By Steve Green

S 510, the Food Safety Modernization Act, may be the most dangerous bill in the history of the US. It is to our food what the bailout was to our economy, only we can live without money.

"If accepted [S 510] would preclude the public's right to grow, own, trade, transport, share, feed and eat each and every food that nature makes. It will become the most offensive authority against the cultivation, trade and consumption of food and agricultural products of one's choice. It will be unconstitutional and contrary to natural law or, if you like, the will of God." ~Dr. Shiv Chopra, Canada Health whistleblower.

YOUR HEALTH

AND THAT OF YOUR LOVED ONES

WHAT IS CODEX?

Codex Alimentarius is Latin for ‘Food Code.’ The Codex Alimentarius Commission, based in

Rome, Italy, and created in 1963, is an international organization jointly run by the Food

and Agricultural Organization (FAO) and the World Health Organization (WHO) of the

United Nations. One of its 27 committees, the Codex Committee on Nutrition and

Foods for Special Dietary Use (CCNFSDU) is responsible for Dietary Supplements and

Special Foods. The CCNFSDU meets once yearly in Germany (its host country) and

the National Health Federation is the only health-freedom group that is a Codexrecognized

organization with the right to attend, submit documents, interact in real time

with other Codex delegates, and speak out at these meetings.

Codex’s published goals are to develop and adopt uniform food standards for its

member countries and to promote the free and unhindered international flow of food

goods, thereby eliminating trade barriers to food and providing food safety.

HOW DOES IT AFFECT THE HEALTH OF U.K. & OTHER CITIZENS?

Unfortunately, implementation of this goal has headed in the WRONG DIRECTION.

WHY?

Because, among other reasons:

• The delegates to the committees are regulatory bureaucrats, largely out of

touch with consumers and influenced by commercial interests adverse to

true health. As a result, they are establishing unhealthy guidelines.

• The U.K. delegate at Codex is no friend to health freedom, rarely speaks

out at the meetings because he/she is subordinate to the European

Commission representative, and generally is friendly to the controlling, antihealth-

freedom position that Brussels has adopted.

• The U.S. delegate – another bureaucrat but with the American Food and

Drug Administration – is no friend of health freedom either. The U.S. FDA

has announced its intention to harmonize U.S. food regulations to

international standards, a position it also took in an October 11, 1995

Federal Register pronouncement.

• In 1994, Codex began the process of establishing “guidelines”

to govern international trade in food supplements. This will be

used to exclude high-potency British, Canadian, and American

supplements and move towards harmonization of the more-liberal U.K. and

U.S.food regulatory regime with the harsh Napoleonic-law-oriented

European regulatory model that only allows ridiculously low-potency and

expensive supplements to be marketed.

• Other Codex-harmonization issues concern food additives, GM

(genetically-modified) foods, food labeling, infant formulas, risk assessment

of food supplements, and other related issues.

WHY IS THE U.K. CODEX DELEGATE NOT FIGHTING FOR YOUR HEALTH

RIGHTS AT CODEX?

In bed with the pharmaceutical industry for years, the U.K. FSA despises any reins on

its arbitrary enforcement powers over food supplements. Unfortunately, as a cozy

friend of the drug companies and with an anti-supplement mentality, the FSA has acted

to suppress supplements in favor of drugs instead. The FSA knows that it is politically

difficult, indeed impossible, to thwart EU Directives coming out of Brussels, so even if it

had the inclination to do so, it takes the easier path of just accepting the EU Food

Supplement Directive and the EU’s intention to mold Codex Alimentarius standards and

guidelines after the EU Food Supplement Directive, which treats food supplements as

toxic drugs. The FSA does not mind applying a drug-like toxicological model to natural,

healthy foods and supplements. Using harsh and restrictive Codex guidelines and other

international, anti-health harmonization rules and regulations is one way for the FSA to

undermine liberal British food law that has, to this date, permitted natural health

products to flourish in a way long absent from Continental Europe.

The NHF has been monitoring Codex meetings since the mid-1990s and actually

present at these meetings since 2000. Having recognized the threat early on, the NHF

obtained official Codex-recognized status as an INGO (International non-governmental

organization), which allows the NHF the right to speak out for health-freedom at these

Codex meetings and against this UK/EU Codex agenda. No other health-freedom

organization has such status, so the NHF is unique in this respect and the lone nongovernmental

voice at Codex for health freedom.

WHAT CAN YOU DO TO HELP FIGHT FOR OUR HEALTH FREEDOMS?

Be persistently vocal and contact your Members of Parliament to complain about the

lack of representation by the FSA and U.K. representatives at Codex meetings.

Remember, politicians do not see the light, they feel the heat. Write your clearlystated

concerns, then call, e-mail, and also fax. Use every approach and do not flag. If

you reside in their district, they will listen to you, as they want your vote and your

money.

Write letters to the editor, educate friends and co-workers. It must be a grass-roots

effort to save our health freedoms as history has shown that we cannot expect

politicians and bureaucrats to do it for us.

To further educate yourself on Codex:

Visit www.thenhf.com (Codex page)

Go to our website for our Codex book, which unmasks the true Codex

agenda in a reader-friendly form.

Join the NHF and support our decade long struggle against the Codex

threat.

HELP THE NHF CONQUER THE CODEX GRIP

DON'T WAIT UNTIL IT'S TOO LATE

KNOW YOUR ENEMY AND WHAT YOU CAN DO TO FIGHT BACK

*******************************

Join the NHF-UK by contacting thenhf@thenhf.com

*******************************

P.O. Box 688, Monrovia, CA 91017 USA~ +1 (626) 357-2181 ~ Fax +1 (626) 303-0642

Website: www.thenhf.com E-mail: contact-us@thenhf.com

Here's a special interview from the 2010 Health and Freedom Conference.

Gary Franchi sat down with the President of the National Health Federation,

Scott Tips to discuss codex and health care.

The EU has passed a directive that comes into full-force

in April 2011:

That all herbal and mineral supplements are to be banned,

All teaching of alternative healing methods will be banned,

And homeopathic colleges dissolved.....etc.

As of this summer it is now forbidden to sell books about using plants and minerals.

If you live in Europe or know people/ family in Europe, please help circulate this, 35 million signatures are needed-NOW!!

We have a feeling that very few are aware of this at all, and have heard of no protests, although remember that legally our human rights are not the same in street protest...But we have the names of the European MP's for the North West of UK ...Dealing with this, well their email address's, just in case you felt like writing something in protest ;-)

chris@chrisdaviesmep.org.uk

brian.simpson@europarl.europa.eu

paul.nuttall@europarl.europa.eu

arlene.mccarthy@europarl.europa.eu

sajjad.karim@europarl.europa.eu

All of these people can be found to represent those based in the North west of UK - in Europe.

But am sure they would'nt mind a few emails from those who felt the need to express their concerns over this matter ;-)

http://www.grammasintl.com/html/products/campaigns.asp

Date: Thu, 11 Nov 2010 15:08:28 +0000

PRESS RELEASE

Codex NRVs are Thrown Back in the Oven for Reheating

The NHF’s Report on the Codex Nutrition Committee Meeting in Santiago, Chile

November 11, 2010

At last year’s meeting of the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) in Dusseldorf, Germany, the National Health Federation (with help from the Indian and Iraqi delegations) was able to stop the advance of those Guidelines on Nutrient Reference Values (NRVs) that would have set low numerical values for vitamins and minerals. Some delegations, especially Australia, were strongly pushing for these “dumbed down” NRVs to go forward. Had they gone forward at that time – as they very nearly did – then we would now be looking at well-advanced Codex NRVs of, for example, 45 milligrams for Vitamin C and 200 IUs for Vitamin D as providing 100% of an adult’s daily nutritional needs.
This week of November 1-5, 2010, the CCNFSDU met once again to debate this and other NRV texts. Some 250 delegates from 80 countries were in attendance, comprised of country functionaries and international non-governmental organizations (INGOs) representatives. The Committee covered other topics too, such as draft guidelines on the addition of essential nutrients to foods and formulated supplementary foods for older infants and children. The latter was a hotly-debated topic.
But for NHF, the NRV issue was the critical one, especially given the victory at the meeting last year. Could we repeat our success? We had thought this year’s fight would be a long, drawn-out one in the full session of the Committee, and had even prepared and submitted extensive written comments to the Committee. (See www.thenhf.com/article.php?id=2584.)
Instead, in just one afternoon, at the special Saturday (October 30^th) meeting of the CCNFSDUWorking Group on NRVs, we were able yet again to keep the dumbed-down NRVs from advancing even one step. Click here to read how this happened.

********************

For further information on Codex, please visit the NHF website (Codex): http://www.thenhf.com/page.php?id=197

********************

National Health Federation: Established in 1955, the National Health Federation is a consumer-education, health-freedom organization working to protect individuals' rights to choose to consume healthy food, take supplements and use alternative therapies without unnecessary government restrictions. The NHF is the only such organization with recognized observer-delegate status at Codex meetings. www.thenhf.com

**************************************

Codex Overview

NHF Codex Book

NHF Codex Overview

(May be used as an article or printed as a handout to educate on Codex)

NHF-UK Codex Overview

(May be used as an article or as a handout to educate on Codex)

NHF Dutch Overview

(May be used as an article or printed as a handout to educate on Codex)

The Codex Alimentarius Commission (CAC),based in Rome, Italy, is an international organization jointly created by the Food and Agricultural Organization (FAO) and the World Health Organization (WHO) of the United Nations. The Codex Committee on Nutrition and Foods for Special Dietary Use (CCNFSDU) is responsible for Dietary Supplements and Medical Foods and is one of 26 separate Codex committees. The CCNFSDU meets once yearly in Berlin, Germany (its host country) and the National Health Federation is a Codex-recognized organization with the right to attend and speak out at these meetings.

The purpose of Codex is to provide a forum to facilitate global trade in foods and promote consumer food safety by developing science based standards and guidelines for use by member countries. Codex guidelines and standards are automatically implemented by the General Agreement on Trade & Tariffs (GATT) of the WHO and become binding for all international trade among GATT signatory countries. The CAC process calls for proposed committee standards and guidelines to be forwarded and approved by the Codex Alimentarius Commission's Executive Committee. When the proposals reach final approval (after an eight-step process), they then become binding on all GATT signatories, including the United States. Thereafter, no GATT-signatory country may use as a trade barrier any standard or guideline that disagrees with a Codex guideline or standard. According to some, it does not mean that all GATT countries must adopt Codex standards for their own domestic use. According to the NHF, we think that Codex guidelines and standards will inevitably supersede domestic laws, including the Dietary Supplement Health and Education Act of 1994.

The National Health Federation supports Codex guidelines and standards that are based on a free-market approach that maximizes freedom and health. In a free-market approach, the consumer is king and can choose to purchase and consume any foods and dietary supplements that he or she wishes. History has shown that the safest food products do not come from a top-down driven, controlled-market economy where an elitist select few decide what is "best" for all of us. Rather, the safest and healthiest individuals are those who are free to choose for themselves what is best for their health. The National Health Federation does not say that a free-market system is perfect. No system is perfect. Instead, the goal is to minimize health errors and disease and a free-market system inevitably leads to such minimization. Recent history has shown centralized, planned economies to be among the unhealthiest for their citizens. And the more that free-market economies themselves are seduced into allowing health-care decisions to be made by elitist planners, the more health and health freedom will suffer. Therefore, the National Health Federation supports a decentralized system of health choices; and the most decentralized system is one where each individual consumer is free to choose what to put into his or her own body.

In the case of Codex, the National Health Federation opposes the current Codex member states who wrongly believe that consumer health will be enhanced by: (1) denying that dietary supplements can benefit normal, healthy people; (2) incorrectly defining dietary supplements as only those vitamins and minerals that the body cannot manufacture itself; (3) restricting the upper-limit amounts of vitamins and minerals, particularly by referring to currently-crude and archaic medical beliefs about nutrients; (4) restricting any physiological benefit information for consumers; (5) restricting the lower-limit amounts of vitamins and minerals that may be consumed by individuals; and (6) creating "positive" and "negative" lists of dietary supplements.

The current direction of Codex is off course and is unfortunately driven by a statist and elitist mentality that thinks it knows what is best for consumer health and protection. Unfortunately, such a mindset comes from the 1930s, 1940s and 1950s kind of "brave new world" thinking that elevated central planners into a form of "God on Earth." That kind of out-dated thinking has caused more misery, death and disease than can possibly be imagined. That is why the National Health Federation supports a Codex process that will free up health knowledge and products for the entire World. A free-market system of choice and knowledge will avoid the errors of central planning that sets standards, however well intentioned, into stone. With the doubling time of knowledge constantly accelerating, mankind cannot afford the "luxury" of getting stuck in health standards established in the 20th Century while new health knowledge and products are discovered almost daily. We also wish that such discoveries continue. The best way to ensure such progress and advancing health is to keep the planners and bureaucrats from straitjacketing dietary supplements with medievalist thinking and restrictions.

STEPPING OVER STRAY DOGS
But watch out for the Codex mess
By Scott C. Tips
November 11, 2010

Santiago de Chile can be a beautiful place, but one of the first things a visitor notices is that it is a city of stray dogs. They are everywhere. No one abuses them. I’ve never seen that happen even once during my two, week-long visits here. But, then, I’ve never seen anyone feed them either. Some are plumpish, but most are lean and hungry. And too many have visible ribcages pushing out against fur.

So, although my main purpose here in Chile has been to attend the 32^nd session of the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU), being held at the Crowne Plaza Hotel in the Santiago downtown area, I find myself saving the extra food from my meals and standing in line at supermarkets to buy pouches and tins of dog food to feed to the stray dogs outside of the Codex meeting hours. I am not trying to pat myself on the back, because it’s what any of us would – should – do; but while observing how invisible these strays are to the Chileans as they go about their daily lives, even when they see me feeding them, it has struck me as something of a curious parallel world to what has been taking place at the Codex meeting.

The Meetings

As you will recall, at last year’s CCNFSDU meeting in Germany, the National Health Federation (with help from the Indian and Iraqi delegations) was able to stop the advance of those Guidelines on Nutrient Reference Values (NRVs)[1]that would have set low numerical values for vitamins and minerals. Some delegations, especially Australia, were strongly pushing for these “dumbed down” NRVs to go forward. Had they gone forward at that time – as they very nearly did – then we would now be looking at well-advanced Codex NRVs of, for example, 45 milligrams for Vitamin C and 200 IUs for Vitamin D as providing 100% of an adult’s daily nutritional needs.[2]

This week of November 1-5, 2010, the CCNFSDU met once again to debate this and other NRV texts. Some 250 delegates from 80 countries were in attendance, comprised of country functionaries and international non-governmental organizations (INGOs) representatives. For the first time since I have been at these Codex meetings, Dr. Rolf Grossklaus was absent, his place as the CCNFSDU Chairman having been taken by Dr. Pia Noble, a woman with considerable Codex experience.

The Committee covered other topics too, such as draft guidelines on the addition of essential nutrients to foods and formulated supplementary foods for older infants and children. The latter was a hotly-debated topic. But for me, the NRV issue was the critical one, especially given the victory at the meeting last year. Could we repeat our success? I had thought this year’s fight would be a long, drawn-out one in the full session of the Committee, and had even prepared and submitted extensive written comments to the Committee.[3] Instead, in just one afternoon, at the special Saturday (October 30^th) meeting of the CCNFSDU Working Group on NRVs, we were able yet again to keep the dumbed-down NRVs from advancing even one step. Here’s what happened.

The Saturday Fight

The Australian delegate chaired the Working Group’s Saturday afternoon session on NRVs and did her usual, admirable job of allowing all viewpoints to be heard. A very-decent person whom I have known for many years now, the Australian delegate nonetheless has a heavily-vested interest in pushing forward the dumbed-down NRVs. She has that bureaucratic risk-assessor’s mindset that vitamins and minerals are dangerous. But more than that, she personally crunched the numbers and gave birth to them. These are her babies.

So it could be no surprise to anyone that the afternoon’s meeting opened with a strong push for the Working Group to recommend that these NRVs go forward as “recommended” to the full Committee on Monday. Of the delegates, the European Union (EU) was the first to speak out and opposed the figures as having been based on old data. The NHF spoke up next and agreed with the EU position, arguing the points made in the NHF’s written comments.

The Chairwoman tried to defend the numbers, while the United States delegate pushed for a review of just a few of the vitamins (Vitamins A, C, and D, and perhaps potassium). IADSA (the International Alliance of Dietary Food Supplement Associations) supported the US proposal, while many others opposed it, calling for a full review. As the NHF delegate, I argued once again for a full review stating that where some values are wrong, then all are suspect and should be revisited. Encouraged, China asked for a higher NRV for selenium. The Australian chairwoman attempted to get China to back down by alleging that countries would still have the right to set their own values. “Do you wish to continue with your request?” she then asked China. In the past, China would have backed down. But not this time. “Yes,” China flatly replied.

Facing increasing opposition, the Chairwoman decided that saving some of her babies was better than losing them all and issued a fiat decision to the Working Group that Vitamins A, C, and D would be referred back to the Food and Agriculture Organization (FAO) and World Health Organization (WHO) for further review, while the remaining NRVs would be accepted as is.

I immediately objected, as did in turn other delegations such as Thailand, China, Mexico, South Africa, Malaysia, and Zimbabwe. The US delegate asked the very-sensible question, “Do we need to look at other authoritative scientific data [and not just that of FAO/WHO]?”

In the end, accepting the inevitable, the Working Group Chairwoman reversed her position and announced that the Working Group would report to the full session of the Committee on Monday its position that all NRVs and their data were to be re-reviewed by FAO/WHO. And with that, the Saturday meeting ended.

Another satisfied Chilean consumer

Heresy at Codex

The regular session of the CCNSFDU opened two days later, and first addressed various other topics before getting down to the business of debating the NRV guidelines and the NRVs themselves. After successfully turning the Committee around to accepting Preamble wording in the Guidelines that broadened the factors a country could use in setting its own NRVs, the NHF was unfortunately unsuccessful in altering the ambiguous wording of Upper Level of Intake of Nutrients (defined as “the maximum level of habitual intake from all sources of a nutrient or related substance judged to be unlikely to lead to adverse health effects in humans”). CCNFSDU Chairwoman Pia Noble said this definition could not be changed since it was taken directly from the Nutritional Guidelines.

In discussing what scientific authority would be the primary source, the delegates largely expressed their continued faith in the FAO and WHO. Some, including NHF, wanted to broaden the scope of the scientific authorities that Codex would use in setting its NRVs. Yet, the near-religious adoration of the FAO/WHO scientific consultations prevailed.

When the Chairwoman finally recognized NHF to speak on the subject of whether or not non-FAO/WHO scientific sources could be considered, I was blunt, “Are we really saying here that there is never an instance where FAO/WHO science is less valid than others at some time? Are we saying that the FAO and WHO are infallible, that they never make mistakes. As NHF has said several times in the past, FAO/WHO put their pants on one leg at a time just like everyone else. We need to go back to the original wording of that language that allowed for other recognized scientific sources to be used even over FAO/WHO. For if other science exists that is better, why shouldn’t it be used even if it is not from FAO/WHO? At the Working Group meeting last Saturday, it was recognized by many of the delegations that in setting the NRVs, the FAO/WHO data is very outdated. So, again, if better science exists, then why not use it? It’s an open secret anyway that the FAO/WHO consultation results are suspect because the experts are cherry-picked and the end results pre-determined. [murmurs of dissent directed to NHF at this point] You may not like what I have to say, but outside this room, the feelings about that science are very different. Many may genuflect at the altar of the FAO/WHO, but why limit yourself when the possibility of better science exists?”

The Committee then took a coffee break. But evidently the effect of my comments was so strong that the WHO representative at the podium felt the need to spend five minutes after the break telling the delegates that I had “mischaracterized” its science and then outlining the steps WHO took to ensure valid scientific results. Not surprisingly, the outlined steps were no refutation whatsoever of what I had said because those steps could still be easily tweaked to obtain biased experts and biased results. I was pleasantly surprised, though, to have some delegates approach me privately afterwards and express their agreement with my comments. As a parting note, on the final day of the meeting, the Chairwoman improperly refused my request to have my comments entered into the CCNFSDU official Report of the meeting. So much for Codex transparency.

NRVs are Thrown Back in the Oven for Reheating

The second day of the Committee’s meeting saw a continuation of its discussion of the NRV Guidelines and NRVs. By this point, the Chairwoman was terribly gun-shy about recognizing NHF to speak. Several times, she refused to do so. Other times, I had to wait for up to 30 minutes after having pushed my call button to be recognized to speak. The former Chairman, Dr. Rolf Grossklaus, started looking pretty good to me in retrospect.

The discussion turned to the actual nutrient reference values for vitamins and minerals, and the US delegate renewed her push for the FAO/WHO to only consider the “more important” of those nutrients. A brief rehash of Saturday’s debate was held, but the Chairwoman came down squarely in favor of the Working Group’s decision to refer all of the vitamin-and-mineral NRVs back to the FAO and WHO for reconsideration.

The NHF spoke up supporting the Chairwoman’s position, and then took the opportunity to challenge the “Physiological Endpoints” used by the FAO/WHO to calculate the “dumbed down” NRVs. One example I gave was the inanity of deciding upon using the halfway point between tissue saturation by Vitamin C and clinical signs of scurvy as the level (45 mg) at which the Vitamin-C values would be set! So, halfway between health and death was to be an acceptable NRV level? Why not simply choose the healthy level? Unfortunately, this is the kind of mindset that usually prevails at Codex.

But not this time. The Committee agreed to refer all of the NRVs back to FAO and WHO for re-review. Of course, it would have been much better to have had the data redone by real clinical scientists and researchers and not just risk assessors. Still, the NRVs were once again held back, so we can be thankful for that much.

We Are the Stray Dogs

As consumers the World over hunger for real nutrition, they are still treated as nothing more than objects to be stepped over. The “experts” think they know better, yet they know nothing. These regulators, posing as defenders of nutritional virtue, are instead pushing for the very guidelines that destroy health. Fixated as they are on assessing false risks associated with vitamins and minerals, they blind themselves to the benefits these nutrients confer. It is a world they do not understand. Even worse, they blindly step over those who need real nutrition. We are nothing but stray dogs to them.

[1] Not to be confused with Maximum Upper Permitted Limits, NRVs are nothing more than souped-up RDAs. These are numerical values assigned to specified nutrients that supposedly reflect the “typical” person’s nutritional needs for that nutrient. By referring to the NRV for a vitamin or mineral, the consumer is supposed to know whether he or she is getting an adequate intake of that nutrient, even if, as in the case of Vitamin C, 100% of the NRV is defined as 45 milligrams! These values are claimed to be set according to rigorous scientific evidence; but, in reality, “science” at Codex levels is often nothing more than a flimsy set of assumptions and erroneous conclusions cobbled together to justify keeping consumers “safe” from “dangerous” vitamins and minerals.

[2] The proposed Codex NRVs are: Vitamin A (dropped from 800 mcg to 550 mcg); Vitamin D (5 mcg or 200 IUs); Vitamin E (8.8 mg); Vitamin K (60 mcg); Vitamin C (dropped from 60 mg to 45 mg); Thiamin (dropped from 1.4 to 1.2 mg); Riboflavin (dropped from 1.6 mg to 1.2 mg); Niacin (dropped from 18 mg to 15 mg); Vitamin B6 (dropped from 2 mg to 1.3 mg); Folate (raised to 400 mcg); Vitamin B12 (2.4 mcg); Pantothenate (5 mg); Biotin (30 mcg); Calcium (raised from 800 mg to 1000 mg); Magnesium (dropped from 300 mg to 240 mg); Iodine (150 mcg); Iron (14.3-43.1 mg depending upon bioavailability); Zinc (dropped from 15 mg to 3.6-11.9, depending upon bioavailability); Selenium (30 mcg); Phosphorus (700 mg); Chloride (2.3 grams); Copper (900 mcg); Fluoride (3.5 mg); Manganese (2.1 mg); Chromium (30 mcg); and Molybdenum (45 mcg).

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International award-winning filmaker Kevin P. Miller of Well TV announced the release of a new documentary about the threat to medical freedom of choice. 'We Become Silent: The Last Days of Health Freedom' details the ongoing attempts by multinational pharmaceutical interests and giant food companies — in concert with the WTO, the WHO and others — to limit the public’s access to herbs, vitamins and other therapies. 'We Become Silent’ is narrated by Dame Judi Dench, the noted UK actress who has won multiple Golden Globe awards, an Oscar, and a Tony for her on-stage work, in addition to dozens of other honors throughout her prestigious career. Plus Dr Robert Verkerk, executive director of ANH, Scott Tips, legal counsel to the US National Health Federation, John Hammell, of the International Advocates for Health Freedom, Dr Julian Whitaker of the Whitaker Wellness Institute, and numerous other health freedom advocates.

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Guests Dounne Alexander MBE (Founder), and Dr Robert Verkerk (Science Director of The Alliance for Natural Health), join forces to expose the dangers of EU Directives coming into force from 1st.January 2010, which threatens to ban valuable natural foods, vitamins, minerals, herbs, ancient traditions, plus take away our Consumer Rights & Health Choice. This video also exposes why many products and natural foods that are healing cancer are being removed from public knowledge and reach, under the guise of 'consumer protection'.
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Guests Dounne Alexander MBE, FRSA (Founder), and Dr Robert Verkerk (Science Director of The Alliance for Natural Health), join forces to expose the dangers of EU Directives coming into force from 1st.January 2010, which threatens to ban valuable natural foods, vitamins, minerals, herbs, ancient traditions, plus take away our Consumer Rights & Health Choice.

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COMMENTS OF THE NATIONAL HEALTH FEDERATION ON THE PROPOSED

DRAFT ADDITIONAL OR REVISED NUTRIENT REFERENCE VALUES FOR LABELLING

PURPOSES IN THE CODEX GUIDELINES ON NUTRITION LABELLING (Comments at Step 3 of the Procedure)

For the 32nd Session of CCNFSDU

October 25, 2010

The National Health Federation (NHF), a non-profit consumer organization, respectfully submits the following comments:

General Overview.

As NHF argued at the last session of CCNFSDU, the proposed draft Nutrient Reference Values (NRVs) are already too low. For example, an NRV for Vitamin C at 60

milligrams is astoundingly low, especially considering, among many other things, that: (1) cigarette smokers alone destroy, on average, 60 milligrams of Vitamin C with

each cigarette smoked; and (2) that this 60-mg level was never established for optimal health in the first place but instead simply as the level that would prevent death

from scurvy caused by Vitamin-C deficiency. NRVs should and must be set for optimal health levels, not subsistence levels.

Therefore, it is extremely embarrassing to see this Committee actually moving away from optimal levels. Instead, some delegations have mistakenly proposed

thatlower NRVs be adopted for certain important vitamins and minerals, including Vitamin C. For example, the Proposed Draft Additional or Revised NRVs for Labelling

Purposes in the Codex Guidelines on Nutrition Labelling suggests reducing the Vitamin A NRV from 800 micrograms down to 550 micrograms, Vitamin C down from an

already-too-low 60 milligrams to 45 milligrams, Thiamin down from 1.4 milligrams to 1.2 milligrams, Niacin from 18 milligrams down to 15 milligrams, Magnesium

down from 300 milligrams to 240 milligrams, and so forth.

While the suggestion to reduce these NRVs may be well-intended, the effect will be disastrous. Many consumers rely upon NRVs (or rather its national equivalent, RDAs

and RDIs) to know whether or not they are obtaining enough of a necessary vitamin or mineral in their diets. They lack the training or general nutritional knowledge about

optimal intake of specific amounts of these nutrients to be able to determine whether their diet is supplying a sufficient quantity or not of a particular vitamin or mineral. In

other words, for them, if they see an NRV of 100% of a nutrient on a label, they will assume that they have consumed an adequate amount of that nutrient for the day,

regardless of what the “hard” milligram or microgram numbers say on a label and regardless of whether or not that NRV is even true for them.

That is why establishing correct and health-optimal NRVs is important and not a task to be taken lightly or through the use of bad science.

Bad Science Is Behind the Current Effort to Downgrade NRVs.

Unfortunately, in setting these NRVs, this Committee is relying upon flawed science.

In its written comments (CX/NFSDU 10/32/4), the delegation of Costa Rica very correctly pointed out that the FAO/WHO expert consultation relied upon by CCNFSDU1 for

these NRVs used 22-year-old data for Vitamin A. NHF has also noted that the data found for other nutrients is similarly out-dated and behind current nutritional

knowledge.

1 Vitamin and Mineral Requirements in Human Nutrition, 2nd edition, FAO/WHO, 2004, at http://whqlibdoc.who.int/publications/2004/9241546123.pdf.

Again, Costa Rica correctly posits that “Equally, for vitamin C, the consultation establishes a value of 45 mg/day instead of the current value of 60 mg/day, and we do not

understand the change because literature reviews indicate that this value could be increased in the future.” NHF concurs with this statement, except that we would not

just say “could be increased in the future” but “should be increased in the future.”

NHF holds that published data sources from nutritional surveys used by the expert consultation are presently insufficient to allow scientifically meaningful values for

global application. Data relating to trace and ultra-trace elements, for example, are particularly inadequate. In the absence of adequate data, there can be no alternative

but to gain interim input from a panel of experts, derived from leading medical doctors practicing in the fields of clinical nutrition and functional medicine.

It would be quite irresponsible to continue such work if the appropriateness and benefits of any values were not considered by a panel of experts with the greatest

expertise in this field. A great concern is that most of the expertise presently being deployed in the development of NRVs is derived from experts in the field of risk

assessment, who utilize primarily published data, based upon highly precautionary models. At no time has clinical expertise been sought, nor has there been

adequate input from experts deeply familiar with the beneficial effects of nutrients and micronutrients, their ability to promote optimum health and minimize risk of

disease. Yet, this incomplete expertise is exactly what this Committee is being asked to rely upon in downgrading its NRVs!

Again, we strongly recommend that an expert panel with relevant and broad clinical expertise be established to allow a meaningful review of proposed values and to then

make proper recommendations to this Committee.

The NRV Levels Should be Increased.

The NHF strongly objects to the lowering of any of the vitamin and mineral NRVs (with the exception of fluoride and iron) as recent science has demonstrated repeatedly

that these nutrients are needed in the daily diet at levels far higher than those provided by NRV amounts.

1 Vitamin and Mineral Requirements in Human Nutrition, 2nd edition, FAO/WHO, 2004, at http://whqlibdoc.who.int/publications/2004/9241546123.pdf.

1. Vitamin A

For example, expanding upon the comments of Costa Rica, we note that the Helsinki Consultation in 1988 set an NRV for Vitamin A of 800 micrograms of retinol

equivalent. In setting this figure, the Consultation took into consideration the relation between carotene and the prevention of cancer, and stated that although this subject

had not yet been resolved from the scientific point of view, it considered that this aspect might lead to an increase in the international recommended daily intakes in the

future when new scientific data was available. Since 1988, however, a large body of scientific evidence has clearly demonstrated that higher intakes of carotenes and/or

pre-formed Vitamin A are protective against the development of a number of cancers.2

2 Cancer Epidemiol Biomarkers Prev. 2003 Aug;12(8):713-20, “Premenopausal intakes of vitamins A, C, and E, folate, and carotenoids, and risk of breast cancer,” Cho

E, Spiegelman D, Hunter DJ, Chen WY, Zhang SM, Colditz GA, Willett WC; Br J Cancer. 2003 May 6;88(9):1381-7, “Dietary intakes of vitamins A, C, and E and risk of

melanoma in two cohorts of women,” Feskanich D, Willett WC, Hunter DJ, Colditz GA; J Biol Regul Homeost Agents. 2003 Jan-Mar;17(1):92-7, “Retinoids in

chemoprevention of cancer,” Verma AK; Plant Foods Hum Nutr. 2002 Fall;57(3-4):319-41, “Palm oil: biochemical, physiological, nutritional, hematological, and

toxicological aspects: a review,” Edem DO.; Asian Pac J Cancer Prev. 2001 Jul-Sep;2(3):215-224, “A Study of Various Sociodemographic Factors and Plasma Vitamin

Levels in Oral and Pharyngeal Cancer in Gujarat, India,” Patel PS, Raval GN, Patel DD, Sainger RN, Shah MH, Shah JS, Patel MM, Dutta SJ, Patel BP; Cancer Sci. 2003

Jan;94(1):57-63, “Serum carotenoids and mortality from lung cancer: a case-control study nested in the Japan Collaborative Cohort (JACC) study,” Ito Y, Wakai K, Suzuki

K, Tamakoshi A, Seki N, Ando M, Nishino Y, Kondo T, Watanabe Y, Ozasa K, Ohno Y; JACC Study Group; Curr Drug Metab. 2003 Feb;4(1):1-10, “Retinoic acid metabolism

and mechanism of action: a review,” Marill J, Idres N, Capron CC, Nguyen E, Chabot GG; J Am Coll Nutr. 1995 Oct;14(5):419-27, “Epidemiologic studies of antioxidants

and cancer in humans,” Flagg EW, Coates RJ, Greenberg RS; Bibl Nutr Dieta. 1995;(52):75-91, “Cardiovascular disease and vitamins. Concurrent correction of

'suboptimal' plasma antioxidant levels may, as important part of 'optimal' nutrition, help to prevent early stages of cardiovascular disease and cancer, respectively,” Gey

KF; Cancer Causes Control. 2001 Feb;12(2):163-72, “Dietary patterns, nutrient intake and gastric cancer in a high-risk area of Italy,” Palli D, Russo A, Decarli A; Soz

Praventivmed. 1989;34(2):75-7, “Vitamins and cancer: results of a Basel study,” Stahelin HB; Am J Epidemiol. 1991 Apr 15;133(8):766-75, “Plasma antioxidant vitamins

and subsequent cancer mortality in the 12-year follow-up of the prospective Basel Study,” Stahelin HB, Gey KF, Eichholzer M, Ludin E, Bernasconi F, Thurneysen J,

Brubacher G; Ital J Gastroenterol. 1991 Sep-Oct;23(7):429-35, “Gastric cancer in Italy,” Cipriani F, Buiatti E, Palli D; EXS. 1992;62:398-410, “Inverse correlation between

essential antioxidants in plasma and subsequent risk to develop cancer, ischemic heart disease and stroke respectively: 12-year follow-up of the Prospective Basel

Study,” Eichholzer M, Stahelin HB, Gey KF; Int J Cancer. 1994 Mar 1;56(5):650-4, “Serum micronutrients in relation to pre-cancerous gastric lesions,” Zhang L, Blot WJ,

You WC, Chang YS, Liu XQ, Kneller RW, Zhao L, Liu WD, Li JY, Jin ML, et al.; Am J Epidemiol. 1994 Mar 1;139(5):466-73, “Nutritional factors and gastric cancer in Spain,”

Gonzalez CA, Riboli E, Badosa J, Batiste E, Cardona T, Pita S, Sanz JM, Torrent M, Agudo A; Int J Cancer. 1994 Jun 1;57(5):638-44. Nutrients and gastric cancer risk, “A

population-based case-control study in Sweden,” Hansson LE, Nyren O, Bergstrom R, Wolk A, Lindgren A, Baron J, Adami HO; Int JCancer. 1995 Mar 16;60(6):748-52,

“Attributable risks for stomach cancer in northern Italy,” La Vecchia C, D'Avanzo B, Negri E, Decarli A, Benichou J; Zhonghua Yu Fang Yi Xue Za Zhi. 1995 Jul;29(4):198-

201, “Relationship between serum micronutrients and precancerous gastric lesions,” Zhang L, Zhao L, Ma J; Int J Cancer. 1996 Apr 10;66(2):145-50, “Prediction of male

cancer mortality by plasma levels of interacting vitamins: 17-year follow-up of the prospective Basel study,” Eichholzer M, Stahelin HB, Gey KF, Ludin E, Bernasconi F;

Cancer Lett. 1999 Feb 8;136(1):89-93, “Serum antioxidative vitamin levels and lipid peroxidation in gastric carcinoma patients,” Choi MA, Kim BS, Yu R; Int J Cancer. 1998

Nov 9;78(4):415-20, “Nutrient intake patterns and gastric cancer risk: a case-control study in Belgium,” Kaaks R, Tuyns AJ, Haelterman M, Riboli E; J Nutr. 2002

Apr;132(4):756-61, “A dietary oxidative balance score of vitamin C, beta-carotene and iron intakes and mortality risk in male smoking Belgians,” Van Hoydonck PG,

Temme EH, Schouten EG.

3 Mastroiacovo P, Mazzone T, Addis A, Elephant E, Carlier P, Vial T, Garbis H, Robert E, Bonati M, Ornoy A, Finardi A, Schaffer C, Caramelli L, Rodriguez-Pinilla E,

Clementi M, “High vitamin A intake in early pregnancy and major malformations: a multicenter prospective controlled study,” Teratology. 1999 Jan;59(1):7-11.

4 Biesalski HK, “Comparative assessment of the toxicology of vitamin A and retinoids in man,” Toxicology 1989;57:117–61).

5 Wiegand UW, Hartmann S, Hummler H, “Safety of vitamin A: recent results,” Int J Vitam Nutr Res 1998;68:411–6 [review].

Although some research exists to suggest that large doses of beta-carotene may possibly be capable of increasing the risk of lung cancer in smokers, we consider that

in view of the many important health benefits to be obtained from higher intakes of carotenes it would be irresponsible for the CCNFSDU to recommend lower intakes for

the entire population, as a means of protecting smokers, when official WHO policy is to substantially reduce the incidence of tobacco use. Tobacco, not carotene, is the

main cause of lung cancer in smokers.

We also consider that the case for Vitamin A being linked to birth defects has been overstated in most cases. In one study, for example, no birth defects were reported

among 120 infants exposed to maternal intakes of Vitamin A greater than 50,000 IU per day.3 In addition, compared to the infants that were not exposed to high maternal

doses of Vitamin A the infants in this study who were exposed to high doses actually experienced a 50% decreased risk for birth defects. In fact, excessive dietary intake

of Vitamin A has been associated with birth defects in humans in fewer than 20 reported cases over the past 30 years.4 Other data suggests that 30,000 IU of Vitamin A

per day should be considered safe for pregnant women.5

In short, the most-recent and up-to-date data indicate that the NRV for Vitamin A should actually be set substantially higher – at a range of 1000 to 1400 micrograms.

2. Vitamin C

Cancer. 1995 Mar 16;60(6):748-52, “Attributable risks for stomach cancer in northern Italy,” La Vecchia C, D'Avanzo B, Negri E, Decarli A, Benichou J; Zhonghua Yu Fang

Yi Xue Za Zhi. 1995 Jul;29(4):198-201, “Relationship between serum micronutrients and precancerous gastric lesions,” Zhang L, Zhao L, Ma J; Int J Cancer. 1996 Apr

10;66(2):145-50, “Prediction of male cancer mortality by plasma levels of interacting vitamins: 17-year follow-up of the prospective Basel study,” Eichholzer M, Stahelin

HB, Gey KF, Ludin E, Bernasconi F; Cancer Lett. 1999 Feb 8;136(1):89-93, “Serum antioxidative vitamin levels and lipid peroxidation in gastric carcinoma patients,” Choi

MA, Kim BS, Yu R; Int J Cancer. 1998 Nov 9;78(4):415-20, “Nutrient intake patterns and gastric cancer risk: a case-control study in Belgium,” Kaaks R, Tuyns AJ,

Haelterman M, Riboli E; J Nutr. 2002 Apr;132(4):756-61, “A dietary oxidative balance score of vitamin C, beta-carotene and iron intakes and mortality risk in male smoking

Belgians,” Van Hoydonck PG, Temme EH, Schouten EG.

3 Mastroiacovo P, Mazzone T, Addis A, Elephant E, Carlier P, Vial T, Garbis H, Robert E, Bonati M, Ornoy A, Finardi A, Schaffer C, Caramelli L, Rodriguez-Pinilla E,

Clementi M, “High vitamin A intake in early pregnancy and major malformations: a multicenter prospective controlled study,” Teratology. 1999 Jan;59(1):7-11.

4 Biesalski HK, “Comparative assessment of the toxicology of vitamin A and retinoids in man,” Toxicology 1989;57:117–61).

5 Wiegand UW, Hartmann S, Hummler H, “Safety of vitamin A: recent results,” Int J Vitam Nutr Res 1998;68:411–6 [review].

Similarly, it is unthinkable to consider lowering the NRV for Vitamin C when the current level of 60 milligrams is not even sufficient to keep the population in optimal

health. Anyone suggesting lowering the NRV for Vitamin C is completely out of touch with the latest science on nutrition and is relying on old and flawed data.

Fortunately, both the delegations of Costa Rica and China point the proper way forward, that is, to increase the NRV. Costa Rica’s position on Vitamin C has already

been discussed above, and the NHF agrees with Costa Rica’s written comments.

In addition, the delegation of China correctly suggested in its written submission to the 31st session of CCNFSDU (CRD 19) that the NRV for Vitamin C be – not

decreased – but increased to 100 milligrams. This kind of foresight is clearly a step in the right direction and an example to follow.

The NHF holds, however, that a strong argument exists for increasing the NRV for Vitamin C even more dramatically. (See NHF’s written comments to CCNSFDU,

submitted as early as June 2004.)

Studies have shown that several population groups have an inadequate intake of Vitamin C, and that deficiencies of ascorbic acid are far more prevalent than is

commonly believed.6 Moreover, patients suffering from dementia,7 epilepsy,8 preeclampsia,9 gallbladder disease,10 schizophrenia,11

6 Chapman KM, Ham JO, Pearlman RA, “Longitudinal assessment of the nutritional status of elderly veterans,” J Gerontol A Biol Sci Med Sci. 1996 Jul;51(4):B261-9; Yin

S, Su Y, Liu Q, Zhang M, “Dietary status of preschool children from day-care kindergartens in six cites of China,” Wei Sheng Yan Jiu. 2002 Oct;31(5):375-8; Weinstein M,

Babyn P, Zlotkin S, “An orange a day keeps the doctor away: scurvy in the year 2000,” Pediatrics. 2001 Sep;108(3):E55; Hampl JS, Taylor CA, Johnston CS, “Intakes of

vitamin C, vegetables and fruits: which schoolchildren are at risk?” J Am Coll Nutr. 1999 Dec;18(6):582-90; Vannucchi H, da Cunha DF, Bernardes MM, Unamuno MR.

Brasil, “Serum levels of vitamin A, E, C and B2, carotenoid and zinc in hospitalized elderly patients,” Rev Saude Publica. 1994 Apr;28(2):121-6; Boulinguez S, Bouyssou-

Gauthier M, De Vencay P, Bedane C, Bonnetblanc J, “Scurvy presenting with ecchymotic purpura and hemorrhagic ulcers of the lower limbs,” Ann Dermatol Venereol.

2000 May;127(5):510-2; Werbach MR, “Nutritional strategies for treating chronic fatigue syndrome,” Altern Med Rev. 2000 Apr;5(2):93-108; Dejmek J, Ginter E, Solansky I,

Podrazilova K, Stavkova Z, Benes I, Sram RJ, “Vitamin C, E and A levels in maternal and fetal blood for Czech and Gypsy ethnic groups in the Czech Republic,” Int J Vitam

Nutr Res. 2002 May;72(3):183-90; Clow CL, Laberge C, Scriver CR, “Neonatal hypertyrosinemia and evidence for deficiency of ascorbic acid in Arctic and subarctic

peoples,” Can Med Assoc J. 1975 Oct 4;113(7):624-6; Sauberlich HE, “Human requirements and needs. Vitamin C status: methods and findings,” Ann N Y Acad Sci.

1975 Sep 30;258:438-50; Dawson KP, Richardson WW, Orsborn CE, “The leucocyte ascorbic acid levels of children in hospital,” N Z Med J. 1977 Feb 23;85(582):141-3.

4; Stephen R, Utecht T, “Scurvy identified in the emergency department: a case report,” J Emerg Med. 2001;21(3):235-237.

7 Tabet N, Mantle D, Walker Z, Orrell M, “Endogenous antioxidant activities in relation to concurrent vitamins A, C, and E intake in dementia,” Int Psychogeriatr. 2002

Mar;14(1):7-15.

8 Sudha K, Rao AV, Rao A, “Oxidative stress and antioxidants in epilepsy,” Clin Chim Acta. 2001 Jan;303(1-2):19-24.

coronary artery disease,12 cerebral vascular disease,13 esophageal, stomach and colorectal cancers14 and gastric cancer,15 have all been found to have significantly

lower levels of Vitamin C than are found in normal healthy people. This suggests that their Vitamin-C needs are greater and that an NRV of 45-60 milligrams would be

insufficient.

9 Kharb S, “Vitamin E and C in preeclampsia,” Eur J Obstet Gynecol Reprod Biol. 2000 Nov;93(1):37-9; Panburana P, Phuapradit W, Puchaiwatananon O, “Antioxidant

nutrients and lipid peroxide levels in Thai preeclamptic pregnant women,” J Obstet Gynaecol Res. 2000 Oct;26(5):377-81.

10 Simon JA, Hudes ES, “Serum ascorbic acid and gallbladder disease prevalence among US adults: the Third National Health and Nutrition Examination Survey

(NHANES III),” Arch Intern Med. 2000 Apr 10;160(7):931-6.

11 Suboticanec K, Folnegovic-Smalc V, Turcin R, Mestrovic B, Buzina R, “Plasma levels and urinary vitamin C excretion in schizophrenic patients,” Hum Nutr Clin Nutr.

1986 Nov;40(6):421-8; Suboticanec K, Folnegovic-Smalc V, Korbar M, Mestrovic B, Buzina R, “Vitamin C status in chronic schizophrenia,” Biol Psychiatry. 1990 Dec

1;28(11):959-66.

12 Delport R, Ubbink JB, Human JA, Becker PJ, Myburgh DP, Vermaak WJ, “Antioxidant vitamins and coronary artery disease risk in South African males,” Clin Chim Acta.

1998 Nov;278(1):55-60; Singh RB, Ghosh S, Niaz MA, Singh R, Beegum R, Chibo H, Shoumin Z, Postiglione A, “Dietary intake, plasma levels of antioxidant vitamins, and

oxidative stress in relation to coronary artery disease in elderly subjects,” Am J Cardiol. 1995 Dec 15;76(17):1233-8; Singh RB, Niaz MA, Bishnoi I, Sharma JP, Gupta S,

Rastogi SS, Singh R, Begum R, Chibo H, Shoumin Z, “Diet, antioxidant vitamins, oxidative stress and risk of coronary artery disease: the Peerzada Prospective Study,”

Acta Cardiol. 1994;49(5):453-67; Gey KF, “Vitamins E plus C and interacting conutrients required for optimal health. A critical and constructive review of epidemiology and

supplementation data regarding cardiovascular disease and cancer,” Biofactors. 1998;7(1-2):113-74; Akkus I, Saglam NI, Caglayan O, Vural H, Kalak S, Saglam M,

“Investigation of erythrocyte membrane lipid peroxidation and antioxidant defense systems of patients with coronary artery disease (CAD) documented by angiography,”

Clin Chim Acta. 1996 Jan 31;244(2):173-80.

13 Chen JH, Liu XJ, Wang QC, Zeng H, Jiang XP, “Study on the changes in endogenous oxidation agents and levels of anti-oxidation agents in patients with cerebral

vascular disease,” Zhongguo Wei Zhong Bing Ji Jiu Yi Xue. 2003 Apr;15(4):232-4.

14 Skrzydlewska E, Kozuszko B, Sulkowska M, Bogdan Z, Kozlowski M, Snarska J, Puchalski Z, Sulkowski S, Skrzydlewski Z, “Antioxidant potential in esophageal,

stomach and colorectal cancers,” Hepatogastroenterology. 2003 Jan-Feb;50(49):126-31; Beno I, Ondreicka R, Magalova T, Brtkova A, Grancicova E, “Precancerous

conditions and carcinomas of the stomach and colorectum – blood levels of selected micronutrients,” Bratisl Lek Listy. 1997 Dec;98(12):674-7.

15 Choi MA, Kim BS, Yu R, “Serum antioxidative vitamin levels and lipid peroxidation in gastric carcinoma patients,” Cancer Lett. 1999 Feb 8;136(1):89-93.

Similarly, the risk of stroke has been shown to increase significantly with a decreased intake of Vitamin C,16 and low levels of ascorbic acid are implicated in the

development of gastric cancer,17 periodontal disease,18 and cardiovascular disease.19 A high intake of ascorbic acid, on the other hand, has been found to be

protective against the development of gastric cancer,20 as well as cancers of the esophagus,21 uterus,22 oral cavity, stomach, pancreas, cervix, rectum, lung,23

breast,24 ovaries,25 and

16 Yokoyama T, Date C, Kokubo Y, Yoshiike N, Matsumura Y, Tanaka H, “Serum vitamin C concentration was inversely associated with subsequent 20-year incidence of

stroke in a Japanese rural community,” The Shibata study. Stroke. 2000 Oct;31(10):2287-94. 17 You WC, Zhang L, Gail MH, Chang YS, Liu WD, Ma JL, Li JY, Jin ML, Hu

YR, Yang CS, Blaser MJ, Correa P, Blot WJ, Fraumeni JF Jr, Xu GW, “Gastric dysplasia and gastric cancer: Helicobacter pylori, serum vitamin C, and other risk factors,” J

Natl Cancer Inst. 2000 Oct 4;92(19):1607-12; Kodama M, Kodama T, “In search of the cause of gastric cancer,” In Vivo. 2000 Jan-Feb;14(1):125-38; Dabrowska-Ufniarz E,

Dzieniszewski J, Jarosz M, Wartanowicz M, “Vitamin C concentration in gastric juice in patients with precancerous lesions of the stomach and gastric cancer,” Med Sci

Monit. 2002 Feb;8(2):CR96-103.

18 Nishida M, Grossi SG, Dunford RG, Ho AW, Trevisan M, Genco RJ, “Dietary vitamin C and the risk for periodontal disease,” J Periodontol. 2000 Aug;71(8):1215-23.

19 Rath M, Pauling L, “Solution to the puzzle of human cardiovascular disease: Its primary cause is ascorbate deficiency, leading to the deposition of lipoprotein (a) and

fibrinogen/fibrin in the vascular wall,” Journal of Orthomolecular Medicine. 1991; 6:125-134.

20 De Stefani E, Boffetta P, Brennan P, Deneo-Pellegrini H, Carzoglio JC, Ronco A, Mendilaharsu M, “Dietary carotenoids and risk of gastric cancer: a case-control study

in Uruguay,” Eur J Cancer Prev. 2000 Oct;9(5):329-34; La Vecchia C, D'Avanzo B, Negri E, Decarli A, Benichou J, “Attributable risks for stomach cancer in northern Italy,” Int

J Cancer. 1995 Mar 16;60(6):748-52; Ekstrom AM, Serafini M, Nyren O, Hansson LE, Ye W, Wolk A, “Dietary antioxidant intake and the risk of cardia cancer and noncardia

cancer of the intestinal and diffuse types: a population-based case-control study in Sweden,” Int J Cancer. 2000 Jul 1;87(1):133-40; Feiz HR, Mobarhan S, “Does vitamin

C intake slow the progression of gastric cancer in Helicobacter pylori-infected populations?” Nutr Rev. 2002 Jan;60(1):34-6; Valle J, Gisbert JP, “Helicobacter pylori

infection and precancerous lesions of the stomach,” Hepatogastroenterology. 2001 Nov-Dec;48(42):1548-51; Zhang L, Blot WJ, You WC, Chang YS, Liu XQ, Kneller RW,

Zhao L, Liu WD, Li JY, Jin ML, et al., “Serum micronutrients in relation to pre-cancerous gastric lesions,” Int J Cancer. 1994 Mar 1;56(5):650-4; Kikuchi S. Epidemiology of

Helicobacter pylori and gastric cancer. Gastric Cancer. 2002;5(1):6-15; Mayne ST, Risch HA, Dubrow R, Chow WH, Gammon MD, Vaughan TL, Farrow DC, Schoenberg

JB, Stanford JL, Ahsan H, West AB, Rotterdam H, Blot WJ, Fraumeni JF Jr., “Nutrient intake and risk of subtypes of esophageal and gastric cancer,” Cancer Epidemiol

Biomarkers Prev. 2001 Oct;10(10):1055-62; Hansson LE, Nyren O, Bergstrom R, Wolk A, Lindgren A, Baron J, Adami HO, “Nutrients and gastric cancer risk. A population-

based case-control study in Sweden,” Int J Cancer. 1994 Jun 1;57(5):638-44; Cohen M, “Ascorbic acid and gastrointestinal cancer,” J Am Coll Nutr. 1995 Dec;14(6):565-

78; Zhang L, Zhao L, Ma J, “Relationship between serum micronutrients and precancerous gastric lesions,” Zhonghua Yu Fang Yi Xue Za Zhi. 1995 Jul;29(4):198-201.

21 Terry P, Lagergren J, Ye W, Nyren O, Wolk A, “Antioxidants and cancers of the esophagus and gastric cardia,” Int J Cancer. 2000 Sep 1;87(5):750-4.

others.26 In this respect it is interesting to note that megadoses of Vitamin C and other nutrients have been shown to significantly reduce the recurrence of tumors in

patients with bladder cancer,27 and that male smokers with a high intake of Vitamin C have been shown to have a lower risk of cancer than male smokers with a lower

intake of Vitamin C.28

Deaths from stomach cancer and cardiovascular disease and cerebrovascular disease are all associated with low levels of Vitamin C;29 in fact, it has been

demonstrated that mortality for all causes of death decreases strongly with an increased intake of Vitamin C.30 A study of 8,453 Americans’ serum ascorbic acid (SAA)

levels and mortality rates from disease, for example, found that those with a normal to high level of SAA had a 21%-25% lower risk of dying from cardiovascular disease,

and that they had a 25%-29% decrease in risk of mortality from all causes compared to those with low levels of SAA.31

22 Flagg EW, Coates RJ, Greenberg RS, “Epidemiologic studies of antioxidants and cancer in humans,” J Am Coll Nutr. 1995 Oct;14(5):419-27.

23 Block G, “Epidemiologic evidence regarding vitamin C and cancer,” Am J Clin Nutr. 1991 Dec;54(6 Suppl):1310S-1314S.

24 Ibid.; Do MH, Lee SS, Jung PJ, Lee MH, “Intake of dietary fat and vitamin in relation to breast cancer risk in korean women: a case-control study,” J Korean Med Sci.

2003 Aug;18(4):534-40; Zhang S, Hunter DJ, Forman MR, Rosner BA, Speizer FE, Colditz GA, Manson JE, Hankinson SE, Willett WC, “Dietary carotenoids and vitamins A,

C, and E and risk of breast cancer,” J Natl Cancer Inst. 1999 Mar 17;91(6):547-56. 25 Fleischauer AT, Olson SH, Mignone L, Simonsen N, Caputo TA, Harlap S, “Dietary

antioxidants, supplements, and risk of epithelial ovarian cancer,” Nutr Cancer. 2001;40(2):92-8.

26 Mirvish SS, “Experimental evidence for inhibition of N-nitroso compound formation as a factor in the negative correlation between vitamin C consumption and the

incidence of certain cancers,” Cancer Res. 1994 Apr 1;54(7 Suppl):1948s-1951s.

27 Lamm DL, Riggs DR, Shriver JS, van Gilder PF, Rach JF, DeHaven JI, “Megadose vitamins in bladder cancer: a double-blind clinical trial,” J Urol. 1994 Jan;151(1):21-

28 Van Hoydonck PG, Temme EH, Schouten EG, “A dietary oxidative balance score of vitamin c, beta-carotene and iron intakes and mortality risk in male smoking

Belgians,” J Nutr. 2002 Apr;132(4):756-61.

29 Eichholzer M, Stahelin HB, Gey KF, “Inverse correlation between essential antioxidants in plasma and subsequent risk to develop cancer, ischemic heart disease and

stroke respectively: 12-year follow-up of the Prospective Basel Study,” EXS. 1992;62:398-410.

30 Enstrom JE, Kanim LE, Klein MA, “Vitamin C intake and mortality among a sample of the United States population,” Epidemiology. 1992 May;3(3):194-202.

31 Simon JA, Hudes ES, Tice JA, “Relation of serum ascorbic acid to mortality among US adults,” J Am Coll Nutr. 2001 Jun;20(3):255-63.

Vitamin C supplements have also been shown to improve the body’s ability to metabolize glucose and lipids and as such are seen as being beneficial to those with Type

II diabetes.32 Similarly, people with higher levels of Vitamin C have been found to have a lower incidence and risk of hyperglycemia.33

Critically-ill surgery patients have been shown to be significantly less likely to experience organ failure, spend less time using mechanical ventilation, and have shorter

times in intensive care units when they are given supplements of Vitamin C and Vitamin E.34

Adequate amounts of Vitamin C (i.e., more than 60 milligrams) have been shown to be an effective treatment for hypertension, both in non-diabetics,35 and in

diabetics,36 and have been found to reduce muscle soreness and improve muscle function after exercise.37

Research has also demonstrated the ability of higher doses of Vitamin C to delay bone loss,38 and to increase bone density.39 Similarly, an increased intake of

Vitamins C and E has been shown to reduce the risk of hip fractures.40

32 Paolisso G, Balbi V, Volpe C, Varricchio G, Gambardella A, Saccomanno F, Ammendola S, Varricchio M, D'Onofrio F, “Metabolic benefits deriving from chronic vitamin c

supplementation in aged non-insulin dependent diabetics,” J Am Coll Nutr. 1995 Aug;14(4):387-92.

33 Sargeant LA, Wareham NJ, Bingham S, Day NE, Luben RN, Oakes S, Welch A, Khaw KT, “Vitamin C and hyperglycemia in the European Prospective Investigation into

Cancer--Norfolk (EPIC-Norfolk) study: a population-based study,” Diabetes Care. 2000 Jun;23(6):726-32.

34 Nathens AB, Neff MJ, Jurkovich GJ, Klotz P, Farver K, Ruzinski JT, Radella F, Garcia I, Maier RV, “Randomized, prospective trial of antioxidant supplementation in

critically ill surgical patients,” Ann Surg. 2002 Dec;236(6):814-22.

35 Hajjar IM, George V, Sasse EA, Kochar MS, “A randomized, double-blind, controlled trial of vitamin C in the management of hypertension and lipids,” Am J Ther. 2002

Jul-Aug;9(4):289-93; Brody S, Preut R, Schommer K, Schurmeyer TH, “A randomized controlled trial of high dose ascorbic acid for reduction of blood pressure, cortisol,

and subjective responses to psychological stress,” Psychopharmacology (Berl). 2002 Jan;159(3):319-24. Epub 2001 Nov 20; Sherman DL, Keaney JF Jr, Biegelsen ES,

Duffy SJ, Coffman JD, Vita JA, “Pharmacological concentrations of ascorbic acid are required for the beneficial effect on endothelial vasomotor function in hypertension,”

Hypertension. 2000 Apr;35(4):936-41; Fotherby MD, Williams JC, Forster LA, Craner P, Ferns GA, “Effect of vitamin C on ambulatory blood pressure and plasma lipids in

older persons,” J Hypertens. 2000 Apr;18(4):411-5.

36 Mullan BA, Young IS, Fee H, McCance DR, “Ascorbic acid reduces blood pressure and arterial stiffness in type 2 diabetes,” Hypertension. 2002 Dec;40(6):804-9.

37 Thompson D, Williams C, McGregor SJ, Nicholas CW, McArdle F, Jackson MJ, Powell JR, “Prolonged vitamin C supplementation and recovery from demanding

exercise,” Int J Sport Nutr Exerc Metab. 2001 Dec;11(4):466-81; Nieman DC, Peters EM, Henson DA, Nevines EI, Thompson MM, “Influence of vitamin C supplementation

on cytokine changes following an ultramarathon,” J Interferon Cytokine Res. 2000 Nov;20(11):1029-35.

Researchers also recommend that people who are smokers, diabetics, pregnant, users of antibiotics, people who ingest alcohol, and users of contraceptives all need to

consume higher-than-normal amounts of Vitamin C.41 Indeed, Vitamin C is depleted in women who use oral contraceptives, which may result in cardiac problems and

thrombosis.42 Since vitamin supplements are routine for pregnancy, they should also be routine for the pseudo-pregnancy of oral contraception.

The list of recent research proving the nutritional benefits of levels of Vitamin C higher than 60 milligrams per day could fill books. They should not need to be repeated

here. However, what evidently does need to be repeated here is that any lowering of the NRV for Vitamin C from 60 mg to 45 mg will only ensure more sickness and ill-

health – the exact opposite of what Codex is supposed to accomplish. Relying on outdated and clearly-flawed science simply because it comes from a cherished

institution is nothing less than dereliction of our duty owed to our fellow citizens.

3. Vitamin D

The science supporting the human need for significantly higher levels of Vitamin D is increasing by leaps and bounds. In particular, the old and out-dated concept that

humans can get by on a daily intake of just 5 micrograms of Vitamin D is dead.

Instead, adequate levels of Vitamin D (i.e., from 25 micrograms up) are recognized as being necessary by such agencies as Health Canada and others. The scientific

evidence supporting this position is extremely well-documented, but NHF will only footnote a small portion of such research here.43 To ignore this science by

establishing below-minimum nutritional requirements for Vitamin D (such as an NRV of only 5 micrograms) borders on negligence, if not worse.

38 Schaafsma A, de Vries PJ, Saris WH, “Delay of natural bone loss by higher intakes of specific minerals and vitamins,” Crit Rev Food Sci Nutr. 2001 May;41(4):225-49.

39 Morton DJ, Barrett-Connor EL, Schneider DL, “Vitamin C supplement use and bone mineral density in postmenopausal women,” J Bone Miner Res. 2001

Jan;16(1):135-40.

40 Melhus H, Michaelsson K, Holmberg L, Wolk A, Ljunghall S, “Smoking, antioxidant vitamins, and the risk of hip fracture,” J Bone Miner Res. 1999 Jan;14(1):129-35).

41 J Dryburgh DR, “Vitamin C and chiropractic,” Manipulative Physiol Ther. 1985 Jun;8(2):95-103.

42 HenleyS, “Women on the pill are opening up a small case of side effects every morning,” Body Forum. 1977 Jan 30;2(7):20.

43 Mezquita Raya P, Munoz Torres M, Lopez Rodriguez F, Martinez Martin N, Conde Valero A, Ortego Centeno N, Gonzalez Calvin J, Raya Alvarez E, Luna Jd Jde D,

Escobar Jimenez F, “Prevalence of vitamin D deficiency in populations at risk for osteoporosis: impact on bone integrity,” Med Clin (Barc). 2002 Jun 22;119(3):85-9;

Rodriguez-Martinez MA, Garcia-Cohen EC, “Role of Ca(2+) and vitamin D in the prevention and treatment of osteoporosis,” Pharmacol Ther. 2002 Jan;93(1):37-49; Lilliu

H, Pamphile R, Chapuy MC, Schulten J, Arlot M,

4. B Vitamins

As with Vitamins A, C, and D above, NHF could submit to this Committee substantial and extensive scientific research in support of its position that the NRVs for Thiamin,

Riboflavin, Niacin, B6, Folate, Pantothenic Acid, Biotin, and B12 should all be increased so as to be in line with the most-recent research showing the need for higher

consumption levels of these important nutrients.44 That the Working Group for this Committee would suggest that the levels for Thiamin, Riboflavin, Niacin, and B6

should be lowered instead of raised indicates that the latest research and science has been overlooked.

The latest scientific research supports the following NRVs for B vitamins: Thiamin (23 to 40 mg); Riboflavin (23 to 40 mg); Niacin (190-200 mg); Pantothenic Acid

(200 mg); B6 (50 mg); B12 (100 mcg); Folate (800 mcg); and Biotin (800 mcg).

Meunier PJ, “Calcium-vitamin D3 supplementation is cost-effective in hip fractures prevention,” Maturitas. 2003 Apr 25;44(4):299-305; Pfeiffer, J Bone Min Res. 2000,

15:1113-6; Trivedi DP, Doll R, Khaw KT, “Effect of four monthly oral vitamin D3 (cholecalciferol) supplementation on fractures and mortality in men and women living in

the community: randomised double blind controlled trial,” BMJ 2003;326:469-72; Chapuy MC, Arlot ME, Duboeuf F, Brun J, Crouzet B, Arnaud S, Delmas PD, Meunier PJ,

“Vitamin D3 and calcium to prevent hip fractures in the elderly women,” N Engl J Med. 1992; 327:1637-1642; Dawson-Hughes B., Harris S. S., Krall E. A., Dallal G. E,

“Effect of Calcium and Vitamin D Supplementation on Bone Density in Men and Women 65 Years of Age or Older,” N Engl J Med 1997; 337:670-676; Fardellone P, Sebert

JL, Garabedian M, Bellony R, Maamer M, Agbomson F, Brazie rM, “Prevalence and biological consequences of vitamin D deficiency in elderly institutionalized subjects,”

Rev Rhum Engl Ed. 1995 Oct;62(9):576-81; Markestad T, “Effect of season and vitamin D supplementation on plasma concentrations of 25-hydroxyvitamin D in

Norwegian infants,” Acta Paediatr Scand. 1983 Nov;72(6):817-21; Zamora SA, Rizzoli R, Belli DC, Slosman DO, Bonjour JP, “Vitamin D supplementation during infancy is

associated with higher bone mineral mass in prepubertal girls,” J Clin Endocrinol Metab. 1999 Dec;84(12):4541-4; Garland CF, Garland FC, Gorham ED, “Calcium and

vitamin D. Their potential roles in colon and breast cancer prevention,” Ann N Y Acad Sci. 1999;889:107-19; Peehl DM, “Vitamin D and prostate cancer risk,” Eur Urol.

1999;35(5-6):392-4; Hypponen E, Laara E, Reunanen A, Jarvelin MR, Virtanen SM, “Intake of vitamin D and risk of type 1 diabetes: a birth-cohort study,” Lancet. 2001 Nov

3;358(9292):1500-3; Munger KL, Zhang SM, O’Reilly E, Hernan MA, Olek MJ, Willet WC, Ascherio A, “Vitamin D intake and incidence of multiple sclerosis,” Neurology.

2004 Jan 13;62(1):60-65; Goldberg P, Fleming MC, Picard EH, “Multiple sclerosis: decreased relapse rate through dietary supplementation with calcium, magnesium

and vitamin D,” Med Hypotheses. 1986 Oct;21(2):193-200; Sasidharan PK, Rajeev E, Vijayakumari V, “Tuberculosis and vitamin D deficiency,” J Assoc Physicians India.

2002 Apr;50:554-8; Bicknel F, Prescott F, The Vitamins in Medicine, third edition. Milwaukee, WI: Lee Foundation. 1953, p.544, 584-591; Vieth, R. (1999), “Vitamin D

supplementation, 25-hydroxyvitamin D concentrations, and safety,” American Journal of Clinical Nutrition, Vol. 69, No. 5, 842-856, May 1999; Marya RK, Rathee S, Lata V,

Mudgil S, “Effects of vitamin D supplementation in pregnancy,” Gynecol Obstet Invest. 1981;12(3):155-61.

44 Indeed, in June 2004, the NHF did submit extensive research supporting its position for higher NRVs for these and other nutrients.

5. Minerals

The same arguments also apply to the mineral NRVs, particularly magnesium and excepting iron. In the case of iron, the NRVs have been set for growing children and

menstruating females, both of which groups require higher iron intake than males and menopausal women. The typical male at age 45 has four times the iron levels in

his body as a woman of the same age and this is a significant factor in increased heart attacks and cancer rates in males versus females. So, in this case, establishing

young-female-friendly NRVs for iron actually harms males and mature females.

In the case of magnesium, however, the suggestion to lower the NRV from 300 milligrams to 240 milligrams is absolutely not supported by the science.

Research shows that dietary magnesium consumption has progressively declined over the past century from an average intake of 475-500 mg in the period 1900-1908

to an average intake of 175-225 mg in the period 1990-2002.45

As such it is hardly surprising that suboptimal intakes of magnesium and outright magnesium deficiencies are now commonplace in many population groups.46

Indeed, a large segment of the U.S.

45 Magnesium Trace Elements 10: 162-28, 1997.

46 Turner RE, Langkamp-Henken B, Littell RC, Lukowski MJ, Suarez MF, “Comparing nutrient intake from food to the estimated average requirements shows middle- to

upper-income pregnant women lack iron and possibly magnesium,” J Am Diet Assoc. 2003 Apr;103(4):461-6; Vaquero MP, “Magnesium and trace elements in the

elderly: intake, status and recommendations,” J Nutr Health Aging. 2002;6(2):147-53; van der Sijs IH, Ho-Dac-Pannekeet MM, “The treatment of hypomagnesemia,” Ned

Tijdschr Geneeskd. 2002 May 18;146(20):934-8; Milionis HJ, Alexandrides GE, Liberopoulos EN, Bairaktari ET, Goudevenos J, Elisaf MS, “Hypomagnesemia and

concurrent acid-base and electrolyte abnormalities in patients with congestive heart failure,” Eur J Heart Fail. 2002 Mar;4(2):167-73; Schimatschek HF, Rempis R,

“Prevalence of hypomagnesemia in an unselected German population of 16,000 individuals,” Magnes Res. 2001 Dec;14(4):283-90; Iannello S, Belfiore F.

Hypomagnesemia, “A review of pathophysiological, clinical and therapeutical aspects,” Panminerva Med. 2001 Sep;43(3):177-209; Deshmukh CT, Rane SA, Gurav MN,

“Hypomagnesaemia in paediatric population in an intensive care unit,” J Postgrad Med. 2000 Jul-Sep;46(3):179-80; Verive MJ, Irazuzta J, Steinhart CM, Orlowski JP,

Jaimovich DG, “Evaluating the frequency rate of hypomagnesemia in critically ill pediatric patients by using multiple regression analysis and a computer-based neural

network,” Crit Care Med. 2000 Oct;28(10):3534-9; Fox CH, Ramsoomair D, Mahoney MC, Carter C, Young B, Graham R, “An investigation of hypomagnesemia among

ambulatory urban African Americans,” J Fam Pract. 1999 Aug;48(8):636-9; Faintuch JJ, Menezes MS, “Magnesium and myocardial infarction. Brazilian aspects,” Rev Hosp

Clin Fac Med Sao Paulo. 1997 Nov-Dec;52(6):333-6; Durlach J, Bac P, Durlach V, Rayssiguier Y, Bara M, Guiet-Bara A, “Magnesium status and ageing: an update,”

Magnes Res. 1998 Mar;11(1):25-42; Durlach J, Bac P, Durlach V, Durlach A, Bara M, Guiet-Bara A, “Are age-related neurodegenerative diseases linked with various types

of magnesium depletion?” Magnes Res. 1997 Dec;10(4):339-53; Singh RB, Rastogi V, Singh R, Niaz MA, Srivastav S, Aslam M, Singh NK, Moshir M, Postiglione A,

“Magnesium and antioxidant vitamin status and risk of complications of ageing in an elderly urban population,” Magnes Res. 1996 Dec;9(4):299-306; Singh RB, Rastogi

V, Niaz MA, Sharma JP, Raghuvanshi R, Moshira M, “Epidemiological study of magnesium status and risk of hypertension in a rural population of north India,” Magnes

Res. 1996 Oct;9(3):173-81; Singh RB, Niaz MA, Ghosh S, Rastogi V,

population may have a chronic latent magnesium deficiency that has been linked to atherosclerosis, myocardial infarction, hypertension, cancer, kidney stones,

premenstrual syndrome, and psychiatric disorders.47 In this respect it should be noted that although serum levels are commonly used to assess magnesium

deficiency, red cells and leucocytes can be still deficient despite normal serum values.48

The value of adequate (i.e., optimal) magnesium levels cannot be overemphasized in the prevention of heart disease and other related health problems.49 The NRV for

magnesium must, therefore, be set at no less than 400 milligrams and preferably 500 milligrams.

For selenium, NHF suggests a range of 70 to 200 micrograms be established as the NRV for this important mineral. Widely deficient from most soils, especially in

Europe,50 the importance of adequate levels of selenium in nutrition cannot be over-emphasized, especially pertaining to cancer prevention.51

Raghuvanshi RS, Moshiri M, “Epidemiological study of magnesium status and risk of coronary artery disease in elderly rural and urban populations of north India,”

Magnes Res. 1996 Oct;9(3):165-72; Bondarev GI, Feoktistova AI, Zemlianskaia TA, “Nutritional status of native and non-native population of Russia's Extreme North and

Far East,” Vopr Pitan. 1993 Mar-Apr;(2):14-8; Davydenko NV, Vasilenko IG, “Magnesium level in food rations and the prevalence of ischemic heart disease among the

population,” Gig Sanit. 1991 May;(5):44-6; Touitou Y, Godard JP, Ferment O, Chastang C, Proust J, Bogdan A, Auzeby A, Touitou C, “Prevalence of magnesium and

potassium deficiencies in the elderly,” Clin Chem. 1987 Apr;33(4):518-23.

47 Elin RJ, “Magnesium metabolism in health and disease,” Dis Mon. 1988 Apr;34(4):161-218.

48 Landon RA, Young EA, “Role of magnesium in regulation of lung function,” J Am Diet Assoc. 1993 Jun;93(6):674-7.

49 Sjogren, A., Edvinsson, L., and Fallgren, B, “Magnesium deficiency in coronary artery disease and cardiac arrhythmias,” J Int Med, 1989;226:213-22; Dubey, A., and

Solomon, R, “Magnesium, Myocardial ischaemia and arrhythmias. The role of magnesium in myocardial infarction,” Drugs, 1989;37:1-7; Altura B, “Magnesium in

cardiovascular biology,” Scientific American May/June 1995;28-35.

50 Murphy J, Hannon EM, Kiely M, Flynn A, Cashman KD, “Selenium intakes in 18-64-y-old Irish adults,” Eur J Clin Nutr. 2002 May;56(5):402-8; Tutel'ian VA,

Khotimchenko SA, “Selenium as an essential and deficient factor in the nutrition of Russian population,” Vestn Ross Akad Med Nauk. 2001;(6):31-4; Kvicala J, Zamrazil V,

Jiranek V, “Characterization of selenium status of inhabitants in the region Usti nad Orlici, Czech Republic by INAA of blood serum and hair and fluorimetric analysis of

urine,” Biol Trace Elem Res. 1999 Winter;71-72:31-9; Kvicala J, Zamrazil V, Cerovska J, Bednar J, Janda J, “Evaluation of selenium supply and status of inhabitants in

three selected rural and urban regions of the Czech Republic,” Biol Trace Elem Res. 1995 Jan-Mar;47(1-3):365-75; Bogye G, Feher J, Georg A, Antti A, “Relationship

between selenium deficiency and high mortality and morbidity of cardiovascular diseases,” Orv Hetil. 1994 Jan 16;135(3):115-8; Sluis KB, Darlow BA, George PM,

Mogridge N, Dolamore BA, Winterbourn CC, “Selenium and glutathione peroxidase levels in premature infants in a low selenium community (Christchurch, New

Zealand),” Pediatr Res. 1992 Aug;32(2):189-94; Maksimovic ZJ, Djujic I, Jovic V, Rsumovic M, “Selenium deficiency in Yugoslavia,” Biol Trace Elem Res. 1992 Apr-

Jun;33:187-96; Kivela SL, Maenpaa P, Nissinen A, Alfthan G, Punsar S, Enlund H, Puska P, “Vitamin A, vitamin E and selenium status in an aged Finnish male

A Range May Also be Appropriate.

The delegation of Egypt stated in its written submission to this Committee (CX/NFSDU 10/32/4) that it “recommends that the NRV values of these elements to be in a

range status (Min. – Max.)” because this would provide countries with the chance to establish specific NRVs most appropriate to their general population’s requirement.

NHF agrees with this range approach as the most practical and accurate fulfillment of Codex’s mission for consumer health and protection.

Where Are the Bodies?

Vitamins and minerals, even in supplement form, are amongst the safest consumer ingredients and products on the planet. Surveys and studies from Canada to the

United States to Europe show significantly fewer adverse events from, for instance, vitamin and mineral food supplements than from any other consumable. In fact,

statistically, a consumer is more likely to die from a lightning strike, a bee sting, or falling from a horse than he or she is from consuming vitamins and minerals.

So, a confusing question is what is the impetus for highly-restrictive limitations on NRVs of vitamins and minerals? Exactly what is Codex protecting the public from? The

following chart shows that the number of adverse reports from the use of multivitamins is relatively small and the number of deaths is zero. What is the need for such

restrictions? Where are the bodies that would warrant the use of so much time, energy, and money to construct “safe” levels for these already extremely safe products?

population,” Int J Vitam Nutr Res. 1989;59(4):373-80; Wasowicz W, Zachara BA, “Selenium concentrations in the blood and urine of a healthy Polish sub-population,” J

Clin Chem Clin Biochem. 1987 Jul;25(7):409-12.

51 Kim YS, Milner J, “Molecular targets for selenium in cancer prevention,” Nutr Cancer. 2001;40(1):50-4; Yu, Shu-Yu et al., “Regional variation of cancer mortality

incidence and its relation to selenium levels in China,” Biol. Trace Elem res. 7:21-29, 1985; Burguera JL, Burguera M, Gallignani M, Alarcon OM, Burguera JA, “Blood

serum selenium in the province of Merida, Venezuela, related to sex, cancer incidence and soil selenium content,” J Trace Elem Electrolytes Health Dis 1990

Jun;4(2):73-7; Schrauzer GN, “Selenium and cancer: a review,” Bioinorg Chem 1976;5(3):275-81; Shamberger RJ, Frost DV, “Possible protective effect of selenium

against human cancer,” Can Med Assoc J. 1969 Apr 12;100(14):682; Shamberger, R. J., and C. E. Willis, “Selenium distribution and human cancer mortality,” CRC Crit.

Rev. Clin. Lab. Sci. (1971) 2:211-221; Duffield-Lillico AJ, Reid ME, Turnbull BW, Combs GF Jr, Slate EH, Fischbach LA, Marshall JR, Clark LC, “Baseline characteristics

and the effect of selenium supplementation on cancer incidence in a randomized clinical trial: a summary report of the Nutritional Prevention of Cancer Trial,” Cancer

Epidemiol Biomarkers Prev. 2002 Jul;11(7):630-9; Combs GF Jr, Clark LC, Turnbull BW, “Reduction of cancer mortality and incidence by selenium supplementation,”

Med Klin (Munich). 1997 Sep 15;92 Suppl 3:42-5.

While the following chart is for the snapshot year 2002, the figures shown here are typical for other years, both before and after. Considering the enormous health

benefits that would accrue from consuming optimal amounts of these natural nutrients, the path forward for this Codex Committee should be clear – adopt higher NRVs

that promote and optimize health.

Annual report of Poison

Control Centers 2002

Number of adverse reports

Number of deaths

Multivitamins

2811

Oral contraceptives

9948

Insulin

1686

Diuretics

7710

Cough and cold remedies

97710

Aspirin (adult)

5249

Acetaminophen (Tylenol)

28991

Alcohol

40782

Antidepressants

92675

255

Source: American Journal Emergency Medicine 20: 391-4

52, 2002

http://www.aapcc.org/2002_poison_center_survey_results.ht

As can be seen above, dietary supplements (the most “extreme” and concentrated way of consuming these nutrients) are far safer than aspirin tablets, other over-the-

counter pain relievers, oral contraceptives, vaccines, and even table salt. In fact, dietary supplements are safer than food (there are millions of cases of food-borne

infection each year and a few thousand deaths from food poisoning). The public’s unhindered access to optimally-dosed vitamin and mineral supplements is critical to

maintaining public health.

If the NRVs are set too low, informed consumers will ignore them on printed food-product labels. However, the problem with too-low NRVs is that a significant portion of

the population will be misled into believing that they are receiving adequate levels of nutrients, when in fact they will, at best, be receiving only the very minimal amount

necessary to stave off immediate death.

Conclusion.

At the last CCNFSDU meeting (31st session), the Chairman and this Committee very wisely chose to hold back for further consideration the “Proposed Draft Additional or

Revised NRVs for Labelling Purposes in the Codex Guidelines on Nutrition Labelling.” It was recognized – as well stated by the delegations of India and Iraq – that more

time was necessary to ensure that the correct values were arrived at.

In setting NRVs, this Committee must –

Use the latest and most up-to-date scientific research

Consider all authoritative scientific sources of data

Not settle for minimal values that are just enough to keep consumers from dying

Raise the NRVs to optimal values that will maximize good health and well-being

Remember that these nutrients are exceedingly safe and their benefits greatly outweigh any possible detriment

Therefore, reject lowering any of the NRVs for Vitamin A, the B Vitamins, Vitamin C, Vitamin D, Magnesium, Zinc, and Selenium.

Buy Codex Book

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Compiled & Edited by Scott C. Tips

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Codex Book Foreword (German translation)

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CODEX ALIMENTARIUS – THE SILENT STALKER OF YOUR HEALTH FREEDOM

NEVER HEARD OF CODEX? THAT'S EXACTLY WHAT THEY WANT

CODEX AGENDA: Only low-potency, “me too” supplements available

that will do nothing for your health

All or most foods genetically-modified

Beneficial supplements unavailable or sold by prescription only

All Coming to You in the Future, if Codex Has its Way

EDUCATE & EMPOWER YOURSELF ABOUT CODEX – PROTECT YOUR HEALTH

AND THAT OF YOUR LOVED ONES

WHAT IS CODEX?

Codex Alimentarius is Latin for "Food Code." The Codex Alimentarius Commission, based

in Rome, Italy, and created in 1963, is an international organization jointly run by the

Food and Agricultural Organization (FAO) and the World Health Organization (WHO) of

the United Nations. One of its 27 committees, the Codex Committee on Nutrition and

Foods for Special Dietary Use (CCNFSDU) is responsible for Dietary Supplements and

Special Foods. The CCNFSDU meets once yearly in Germany (its host country) and

the National Health Federation is the only health-freedom group that is a Codexrecognized

organization with the right to attend and speak out at these meetings.

Codex’s published goals are to develop and adopt uniform food standards for its

member countries and to promote the free and unhindered international flow of food

goods, thereby eliminating trade barriers to food and providing food safety.

HOW DOES IT AFFECT THE HEALTH OF U.S. & OTHER CITIZENS?

Unfortunately, implementation of this goal has headed in the WRONG DIRECTION.

WHY?

Because, among other reasons:

•The delegates to the committees are regulatory bureaucrats, largely out of

touch with consumers and influenced by commercial interests adverse to

true health. As a result, they are establishing unhealthy guidelines.

•The U.S. FDA delegate at Codex is no friend to health freedom, as shown

when it announced the FDA’s intention to harmonize U.S. food regulations

to international standards, a position it also took in an October 11, 1995

Federal Register pronouncement.

•In 1994, Codex began the process of establishing “guidelines”

to govern international trade in food supplements. This will be

used to exclude high-potency American supplements and move

towards harmonization of the more-liberal U.S. food regulatory regime with

the harsh European regulatory model that only allows ridiculously lowpotency

and expensive supplements to be marketed.

•Other Codex-harmonization issues concern food additives, GM

(genetically-modified) foods, food labeling, infant formulas, risk assessment

of food supplements, and other related issues.

WHY IS THE U.S. FDA CODEX DELEGATE NOT FIGHTING FOR YOUR HEALTH

RIGHTS AT CODEX?

The U.S. FDA despises the 1994 DSHEA Act – which, by removing the FDA’s arbitrary

enforcement powers, has protected our rights to healthy food supplements.

Unfortunately, as a cozy friend of the drug companies and with an anti-supplement

mentality, the FDA has acted to suppress supplements in favor of drugs instead. The

FDA knows that it is politically difficult to attack DSHEA directly, so it and its allies try

indirectly to eliminate DSHEA by having supplements treated as drugs rather than as

foods. The FDA is using harsh and restrictive Codex guidelines and other international,

anti-health harmonization rules and regulations as one way to undermine DSHEA.

The NHF has been monitoring Codex meetings since the mid-1990s and actually

present at these meetings since 2000. Having recognized the threat early on, the NHF

obtained official Codex-recognized status as an INGO (International non-governmental

organization), which allows the NHF the right to speak out for health-freedom at these

Codex meetings and against this U.S. FDA and Codex agenda. No other healthfreedom

organization has such status, so the NHF is unique in this respect and the lone

non-governmental voice at Codex for health freedom.

WHAT CAN YOU DO TO HELP FIGHT FOR OUR HEALTH FREEDOMS?

Be persistently vocal and contact your legislators to complain about the lack of

representation by the FDA and Dr. Barbara Schneeman at Codex meetings.

Remember, politicians do not see the light, they feel the heat. Write your clearly

stated concerns, then call, e-mail, and also fax, use every approach. If you reside in

their district, they will listen to you, as they want your vote and your money.

Write letters to the editor, educate friends and co-workers. It must be a grass-roots

effort to save our country as history has shown that we cannot expect politicians and

bureaucrats to do it for us.

To further educate yourself on Codex:

Visit www.thenhf.com (Codex page)

Go to our website for our just-released Codex book, which unmasks the

true Codex agenda in a reader-friendly form.

Join the NHF and support our decade long struggle against the Codex

threat.

HELP THE NHF CONQUER THE CODEX GRIP

DON'T WAIT UNTIL IT'S TOO LATE

KNOW YOUR ENEMY AND WHAT YOU CAN DO TO FIGHT BACK

About the National Health Federation

Established in 1955, the National Health Federation is a consumer-education,

health-freedom organization working to protect individuals' rights to choose to

consume healthy food, take supplements and use alternative therapies without

government restrictions. With consumer members all over the world, and a Board

of Governors and Advisory Board containing representatives from 6 different

countries, the Federation is unique is being the only consumer health freedom

organization in the world to enjoy official observer status with the Codex

Alimentarius Commission.

P.O. Box 688, Monrovia, California 91017 USA~ 1 (626) 357-2181 ~ Fax 1 (626) 303-0642

Website: www.thenhf.com E-mail: contact-us@thenhf.com

MANIPULATIVE POLITICS AT CODEX, WHERE FORM REIGNS OVER FUNCTION
July 12, 2010

PRESS RELEASE

The Codex Alimentarius Commission (CAC) opened its 33rd session on Monday, July 5th, at the Centre International de Conferences in Geneva, Switzerland, with a full agenda of food-standard topics to be discussed. Except for those spells during which vice-chairmen ran the meeting for practice, the CAC Chairwoman Karen Hulebak steered the meeting down its bobsled course with the National Health Federation (NHF) as a very active and noticed participant in the debates.

Among many other issues, the Commission debated the proposed Codex standard for ractopamine maximum residue levels (MRLs). Stuck at the final Step 8, and balancing on the edge of adoption by CAC, these standards are strongly opposed by the European Union, Russia, China, Turkey, and other member-country delegations as well as all consumer INGOs.

Ractopamine is a veterinary drug developed by a subsidiary of drug company Eli Lilly. It is approved in 22 countries, but either banned or not approved for use in 160 countries worldwide. Administered in the feed of animals in the last few weeks before they are slaughtered, this drug “beefs up” the animal so that more will be paid for them at market. Lost in the shuffle are any concerns about the health and welfare of the animals themselves as well as the health of the humans who consume ractopamine-saturated meat.

As argued by NHF delegate Scott Tips during the Commission’s sometimes heated debates, “This debate is being framed in a rigged way that is dishonest. Our goal here is not compromise and consensus, those are just tools, not an end in themselves. The goal as stated by you [indicating Chairwoman Hulebak] at this morning’s opening session is ‘to protect the health of consumers.’ Unfortunately, there always seems to be a push for adoption no matter what. This Commission has a habit of rubberstamping, rubberstamping, and rubberstamping what has been done below in the committees. Yet sometimes there can be no compromise or consensus reached, and you just have to stand back and say ‘no,’ ‘no more.’ That is what has happened here. This product, ractopamine, has been banned in 160 countries and there are delegates here representing 2.5 billion persons who are saying no to ractopamine. This is not a safe product. Others seem to want to push commercial interest over health instead. Some have argued that if we don’t approve a standard here than the credibility of the whole Codex system will be called into question. But, what will bring into question the whole system more than anything else would be to crank out a standard that leads to harming thousands of people – that would be far worse than simply failing to adopt a standard! We therefore agree with the comments of the delegates of Norway, the EU, China, and Russia, who are trying to protect the health of their citizens by taking a firm stand here against ractopamine.”

[For the Full Report and outcome of the debates click here.]

Please send this e-mail to everyone on your list so that they may know the truth about Codex events.

********************

*** PLEASE CONSIDER DONATING SO THAT WE MAY CONTINUE OUR FIGHT AT CODEX.

THE NHF EXISTS TOTALLY ON MEMBERSHIP FEES AND DONATIONS. ***

********************

For further information on Codex, please visit the NHF website (Codex): http://www.thenhf.com/codex.html

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