Annex
Letter to the Chairman, Better Regulation
Task Force, from the Director of Political Campaigns, Consumers
for Health Choice
VITAMIN B6
We met recently with your colleague Mr Stephen
Alambritis of the Federation of Small Business who suggested that
we should write to you to register our deep concern about the
Government's proposals to introduce severe and completely unnecessary
restrictions on the retail sale of vitamin B6.
I enclose information which sets out the background
to this issue and demonstrates the reasons why virtually all those
who look at the subject accept that the recommendations from the
Committee on Toxicity on which the Minister for Food Safety has
based his decisions were formed on the basis of flawed science
and an inappropriate methodology.
Clearly, the detailed scientific arguments are
not ones with which we would expect your Task Force to concern
itself, but we do feel that there are several points about the
proposed new regulations, publication of the draft of which is
now imminent, about which you should be aware and in connection
with which you may wish to consider making representations to
the Prime Minister:
(A) ENFORCEMENT
The intention of the proposed regulations is
to "protect" consumers from the alleged dangers of consuming
dangerous levels of dietary supplements. They will do no such
thing. If consumers wish to consume, say, 100 mg of vitamin B6
daily the restriction that tablets or capsules may only contain
10 mg will simply lead to the consumption of 10 tablets, at greater
expense and inconvenience.
(B) PROPORTIONALITY
The Minister announced his decision in July
1997. If he and his advisers really believed that vitamin B6 posed
a serious and substantial risk to public health then the regulations
would have been brought into force immediately. It is clear that
it will at best now have taken almost a year between the announcement
of the ban and its implementation. If serious harm was being caused,
then dozens if not hundreds of cases would have come to light
during this period. They have not, and it is clear both from this
demonstrable fact and from the Minister's own willingness to allow
repeated delays in implementation that the proposed restrictions
are completely disproportionate to any alleged problem.
(C) CONSISTENCY
Food safety policy should be based upon sound
science, and criteria applied when determining the "safe"
levels of B6 should be suitable for other nutrients. They are
not. Furthermore, alcohol, tobacco products, salt and many other
products intended for human consumption pose a much greater risk
to public health even at the levels at which they are usually
available. For many people, for example, excessive consumption
of alcohol would be fatal in a very short period of time, as would
excessive consumption of salt, and for that matter even water.
The devastating effects of tobacco are well documented. To subject
vitamin supplements to such draconian regulation as that proposed,
particularly when industry is already operating a voluntary maximum
dosage level of 200 mg, is completely inconsistent and makes a
mockery of public policy in this area.
(D) ECONOMIC
IMPACT
The economic impact of the regulations should
not be underestimated. Not only will many simple vitamin B6 products
need to be withdrawn and reformulated, but a huge range of multi-vitamin
and multi-supplement products will also be affected since they
routinely include vitamin B6 at greater than the proposed new
levels. The cost to industry will run into millions of pounds,
and hundreds of jobs will be lost in both the manufacturing and
the retail sector.
Consistent with recent statements of Government
policy we believe that the era of the "nanny state"
should be over, and that Government's role should be to ensure
that consumers have the information which they need in order to
make informed decisions for themselves. Over 10,000 consumers
have so far written to the Ministry of Agriculture, Fisheries
and Food to register their concern about and opposition to the
proposals, and the Minister has also received 1,200 letters from
Members of Parliament on the subject. None of them supported the
proposals.
For all these reasons, we do hope that you will
be willing to look into this matter and to urge the Government
not to introduce measures which are at best ill-considered and
at worst disproportionate and inconsistent, which would have a
major and adverse economic impact, and which could not in practice
be enforced.
Any help that you can give in this important
matter would be very much appreciated.
With kind regards and all good wishes.
16 February 1998
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