APPENDIX 7
Letter to the Clerk of the Committee from
Consumers for Health Choice
We very much welcome the Committee's enquiry
into EQUAL (Extend Quality Life) and are grateful for the opportunity
to present this written submission.
1. WHAT IS
CHC?
Consumers for Health Choice (CHC) is a non-profit
making Europe wide alliance of consumer organisations, practitioner
organisations and companies. CHC is just five years old, and works
to protect the rights of millions of consumers to have continued
easy access to safe dietary supplements and natural health products
of their choice, at competitive prices. We have over 6,000 members,
plus a data base of more than 250,000 supplement consumers who
wish to defend their right to take responsibility for their own
health without the use of pharmaceutical drugs.
As an organisation looking after consumers'
interests, we have detailed experience of the vital role played
by higher dose vitamins and minerals in protecting and maintaining
the public's health. Other food supplements and alternative therapies
also contribute greatly to the prevention of disease and the treatment
of age related ailments.
2. THE POPULATION
In 1995, there were less than 9 million people
aged over 65 in the UK. By 2030 there will be 50 per cent more—almost
14 million.
In 1991, 21 per cent of the workforce was aged
20-34. By 2001, this will have dropped to 14 per cent.
When the National Health Service was designed,
life expectancy was around 50 years. Today it is around 80 years.
The NHS was set up when 60 per cent of the population was under
20. Soon, 50 per cent of the population will be over 50.
By 2031 the proportion of those aged over 60-65
compared with those of working age will have doubled.
By 2021, 41 per cent of the population will
be aged over 50 years.
(Source: Age Concern, 1999).
3. BACKGROUND
The results of many studies carried out in the
past few years have shown that dietary supplements have the potential
to increase longevity. It is not just a question of living longer,
but living better—a healthier, happier, more productive
and creative life—and key nutrients have been shown to enhance
energy, immunity, cognitive function and overall well-being.
If life were split into two stages, development
and decline, the turning point would be around age 33. At this
point, if nothing is done to halt or reverse the changes, the
body gradually begins to lose muscle and, with it, strength. Aerobic
capacity starts to diminish. Metabolism slows, digestive tracts
become less able to absorb nutrients fully. Bones become more
fragile—and the immune system weakens.
All this happens if you do nothing, if you make
no attempt to offset the ageing process. While the majority of
people only start to think of taking care of their health once
they reach retirement age, such actions need to start a great
deal earlier if quality of life is to be maintained. While it
is never too late to make lifestyle and dietary changes, the three
important factors for a long and healthy life: regular exercise,
stress management and a healthy diet, seem to be regarded as more
desirable than essential.
These three factors are all within our own control,
and yet, although they generally reach the New Year's resolution
lists, most people never succeed with these changes for very long.
We are most fortunate that in the UK we can easily purchase higher
dose vitamins and minerals—probably the single most important
factor in improving and maintaining good health and well being,
but it is unfortunate that very little training is given to the
orthodox medical profession about nutrients—and even less
responsible information given to the public about the benefits
of higher range supplements. The recent Mintel (May/June 1999)
report on the sector Complementary Medicines says that out
of 979 adults surveyed, 57 per cent would like to use supplements,
but were unsure of what to buy. Mintel says that more information
on the health benefits of products, and which ailments they can
be used to ease, should be better communicated through product
labels, as well as at the point of sale and through advertising.
Mintel acknowledges that makers of unlicensed products (including
herbal remedies and dietary supplements) are held back by current
health claims legislation.
Because dietary supplements are classified as
foods, manufacturers cannot make health-related claims for them,
even though there is an overabundance of good science world-wide
to confirm their advantages. Age related illnesses such as Osteoporosis,
Heart disease, Cancer, Dementia, Arthritis, Rheumatism and others
could all be improved or their onset delayed by long term use
of higher range food supplements. While our National Health Service
struggles to treat people when they fall ill, there would be colossal
savings in both time and resources to be made if we could slow
down the ageing process and stop the majority of the population
from falling ill in the first place.
4. BENEFITS OF
DIETARY SUPPLEMENTS
OSTEOPOROSIS (brittle bone disease) is known
as the "Silent Killer", and those diagnosed with this
disease have either failed to attain optimal bone mass during
their first three decades, or have suffered from a rate of bone
loss that has exceeded that of bone build-up thereafter. Both
sexes will be affected, but as many as 50 per cent of women will
suffer from osteoporosis at some point in their lifetime. Most
people recognise the almost inevitable loss of height that occurs
with increasing age, and indications are that after age 40-50,
bone loss is 20-30 per cent of the total bone mass in men—and
as much as 40-50 per cent in women.
The bones of the hands, hips and vertebrae show
greater loss than those of the skull and legs, but no bone is
totally spared. The accentuation of bone loss produces osteoporosis,
and with it come severe pain, fractures and postural distortions.
A large number of other medical conditions may be accompanied
by osteoporosis, and some people may be predisposed to osteoporosis
by genetics. However, the far most common origin of osteoporosis
is the excess bone loss that has no distinct medical origin, but
which is related to various features of modern lifestyles.
The best known nutrient for Osteoporosis is
Calcium, and the latest research shows that for bone building,
calcium should be taken with the mineral magnesium. A report in
The Lancet (1998,351;9098:269) shows that women can help
to protect their bones by taking a calcium supplement. An earlier
report published in The American Journal of Clinical Nutrition
(1991,54:261S-5S) states "from what is known about calcium
requirements in childhood and adolescence, an intake in males
of 1000mg daily, and 850mg daily in females would not be sufficient
to satisfy their needs, particularly during adolescence. In children
consuming lower amounts, it is unlikely that optimal bone mass
is achieved, leading to high risk of osteoporosis in later life".
The importance of calcium in extending the quality
of life should not be underestimated. Results from studies show
that taking calcium supplements alone reduces bone loss in postmenopausal
women by as much as 40 per cent—typical supplementary intakes
of calcium are 1200-1500mg daily, almost double the Recommended
Daily Amount (RDA). RDAs were introduced almost 60 years ago,
as the minimum amount of a nutrient required by the body to protect
against nutritional deficiency diseases. Many people believe that
the RDA represents the safe level at which a nutrient can be consumed,
but this is not the case. Safety levels for all nutrients vary,
and can be more than a hundred times the RDA.
CANCER is the most feared of all illnesses,
though it is not the primary cause of death. One in three people
in Britain will have cancer diagnosed at some time during their
life (more than 40,000 every year), and one in four of those diagnosed
will die from cancer. In women, breast cancer is the most common
cancer, although the gap between women with breast cancer and
women with lung cancer is closing—due to the increased levels
of smoking among women, particularly younger women. Lung cancer
is the most common cancer affecting men. Scientific studies have
shown that a nutrient rich diet can prevent up to 80 per cent
of colon, breast and prostate cancers—colon cancer being
the most preventable.
The National Academy of Sciences (US) estimates
that 60 per cent of women's cancers and 40 per cent of men's cancers
are related to nutritional factors. The cancers most closely associated
with nutritional factors are breast and endometrial cancer in
women, prostate and gastrointestinal cancers in men. The value
of a low fat, high fibre, high complex carbohydrate diet in cancer
prevention is well documented, as is the fact that alcohol abuse
and smoking increases the cancer risk. It is common knowledge
that large pockets of the population do not eat a nutrient rich
diet, and even if they did, the amounts of nutrients, particularly
antioxidants, needed to help prevent age related illnesses could
not be obtained from diet alone. Supplementation would be required,
on a long-term basis, using higher range doses.
For several nutrients, the lower their intake;
the greater the risk of developing certain cancers. (Melvyn R.
Werbach, MD, The Nutritional Influences on Illness (1996;
124)).
Oxidation within the body is a leading culprit
in the two diseases we are most likely to die from, cancer and
heart disease. Substances known as antioxidants, such as vitamin
C, vitamin E, beta-carotene, selenium and others, help to prevent
this cellular breakdown.
Vitamin C is a critical supporter of the immune
system and is essential to repair connective tissue. Vitamin C
is also crucial to the body's stress responses, and its antioxidant
activity probably explains its effects in preventing both heart
disease and some cancers. A general review article published in
The American Journal of Clinical Nutrition (1991,54:1310S-14S)
states that "approximately 90 epidemiologic(al) studies have
examined the role of vitamin C rich foods in cancer prevention,
and the vast majority have found statistically significant protective
effects. Evidence is strong for cancers of the oesophagus, oral
cavity, stomach and pancreas. There is also substantial evidence
of a protective effect in cancers of the cervix, rectum and breast.
Even in lung cancer . . . there is recent evidence of a role for
vitamin C".
Although Vitamin E is best known in its protective
role against heart disease, it also helps protect against some
cancers. An observational study published in The American Journal
of Clinical Nutrition (1991,53:283S-6S) reports that "pre-diagnostic
blood serum samples from 766 cases of cancer, and 1,419 matched
controls were analysed. Individuals with a low level of vitamin
E had a 1½-fold risk of cancer, compared to those with a
higher level. The strength of the association between the blood
serum vitamin E level and the cancer risk varied for different
sites, and was strongest for some gastrointestinal cancers and
for the combined group of cancers unrelated to smoking. The association
was strongest among non-smoking men and among women with low levels
of blood serum selenium".
Studies of Beta-carotene, which is converted
to vitamin A in the body, have also shown an association with
a reduction in heart disease as well as an improvement in memory
and cognitive function.
Beta-carotene has also been shown to be protective
against some cancers. A review article published in The Journal
of Nutrition (1989,119:116-22) reported that "low intakes
of carotene and carotene-rich fruits and vegetables are consistently
associated with an increased risk of lung cancer in both prospective
and retrospective studies, and low levels of serum or plasma beta-carotene
are consistently associated with the subsequent development of
lung cancer. However, the importance of other carotenoids, other
constituents of fruits and vegetables, and other nutrients whose
levels in the blood are partially correlated with those of beta-carotene
has not been adequately explored. Also, smoking is associated
with reduced intake of carotenoids and lowered blood beta-carotene
levels, and has not always been adequately controlled. While prospective
and retrospective studies suggest that carotenoids may reduce
the risk of certain other cancers, too few studies have looked
at these sites to examine the consistency of the evidence".
HEART DISEASE is no longer strictly a man's
worry; it is now the leading cause of death in Britain for both
men and women. High blood pressure (hypertension), high levels
of cholesterol and elevated homocysteine levels all contribute.
Hypertension is an insidious condition that
can have a detrimental effect on the heart, kidneys, brain and
other major organs, yet it causes almost no symptoms until it's
too late. It is estimated that 50 per cent of people whose hypertension
is left untreated die of coronary artery disease and heart failure.
Better education would enable most people to control and manage
hypertension easily without the use of drugs. Along with lifestyle
changes, perhaps the adoption of a meat free diet, dietary supplements,
particularly Omega-3 Fatty Acids (fish oils) and specific minerals
show significant promise in reducing high blood pressure.
Calcium has been shown in studies to not only
lower blood pressure, but also to help prevent high blood pressure.
Some scientists have stated that calcium counteracts the effects
that sodium has on blood pressure. Magnesium is another valuable
mineral for controlling hypertension; it works by relaxing and
smoothing the muscle of blood vessels. But perhaps the most effective
mineral is Potassium, which is why the consumption of fresh fruits
and vegetables is so important as many of them contain high levels
of potassium. An observational study published in The American
Journal of Clinical Nutrition (1983,37:775-762) reports that
98 vegetarians were compared to a matched group of non-vegetarians.
The average BP was 126/77 for the vegetarians and 147/88 for the
control group, a significant difference. Only 2 per cent of the
vegetarians had hypertension (BP above 160/95) compared to 26
per cent of the non-vegetarians. Both groups had a similar sodium
intake and excreted similar amounts of sodium, while potassium
intake and excretion was significantly higher in the vegetarians;
thus it appears that the high potassium intake of vegetarians
could account for the diet's anti-hypertensive effect.
High cholesterol is the risk factor most people
connect to coronary heart disease. Diets low in saturated fats,
and rich in fruit and vegetables, along with regular exercise,
can reduce cholesterol levels. Many women have become fat-phobic,
but healthy fat is not the enemy. Special low-fat diets for lowering
cholesterol are recommended by the orthodox medical professionals,
but they are often difficult to follow, and very few people adhere
to them consistently—which means they are generally unsuccessful.
Some prescription drugs can also lower cholesterol, but their
side effects can include heart failure, blurred vision, muscle
aches, fatigue and impotence.
This is an area where accurate information about
specific higher range supplements would be of great benefit. Scientific
studies carried out over many years have shown that vitamin C,
vitamin E, chromium, niacin (B3) and carotenoids (lycopene and
beta-carotene) have the ability not just to lower cholesterol
levels, but also to inhibit the body's production of "bad"
cholesterol. In the 1950's, Abraham Hoffer, M.D., Ph.D. (US) discovered
that the niacin form of vitamin B3 could reduce cholesterol levels.
This essential vitamin was then approved in America by the FDA
as a cholesterol lowering drug. Effective doses range from 1500-3000mg
daily—more than a hundred times the RDA of 18mg. An experimental
placebo-controlled study published in Arch International Medicine
(1997,151:1424-32) supports high dose niacin supplementation.
In this randomised study, patients with elevated LDL cholesterol
levels consumed either 2000, 1500, 1250 or 1000mg daily of niacin
in a wax-matrix sustained release form, and were compared to placebo
and diet treated groups. Patients who consumed niacin in doses
of 1500mg daily, or more, showed significant reductions in LDL
cholesterol. Total cholesterol dropped 18.4 per cent and 13.3
per cent, and the ratio of total cholesterol to HDL cholesterol
dropped 20.4 per cent and 19.4 per cent in the 2000mg and 1500mg
groups respectively. Improvements were also noted in HDL cholesterol
and triglyceride levels. Several liver enzymes, including AST,
lactate dehydrogenase and alkaline phosphatase, increased as LDL
cholesterol decreased, but only in the patients receiving niacin,
suggesting that the liver may be the site of niacin's effects
on lipids. Side effects were minimal, with a drop-out rate of
only 3.4 per cent.
Homocysteine is a toxic amino acid, but there
is very little awareness of it by most people. It is another substance
in the blood that, like cholesterol, is related to the risk of
heart disease and responds to good nutrition and appropriate dietary
supplements. We now know that keeping homocysteine levels low
is as important to heart health as maintaining the right cholesterol
levels. It was in 1969 that Kilmer McCully, MD (US), then a professor
at Harvard Medical School, suggested that the accumulation of
homocysteine may start the process of atherosclerosis, a series
of abnormal changes in the walls of blood vessels that gradually
blocks the flow of blood. Since then, substantial evidence from
both animal and human studies confirm the dangers of this toxic
substance.
It is normal for us to produce homocysteine,
but it usually gets broken down quickly so that the levels don't
get high enough to do any real harm. However, many people accumulate
homocysteine because their bodies are unable to destroy the amino
acid rapidly. Homocysteine overload, far from being rare, is found
in 20-40 per cent of the victims of coronary heart disease. Fortunately,
mildly elevated homocysteine levels can be brought back to normal
in most cases by supplementation. Of central importance are some
of the B-complex vitamins, particularly folic acid, vitamin B6
and vitamin B12. According to an experimental study published
in Atherosclerosis (1990,81(1):51-60) "20 patients
below age 55 with blocked arterial disease of cerebral, carotid,
or aorta-iliac vessels found to have impaired homocysteine metabolism
were treated with pyridoxine hydrochloride (B6) 240 mg daily (120
times the RDA of 2 mg) and folic acid 10mg daily (50 times the
RDA of 200mcg). After four weeks, fasting homocysteine was reduced
by a mean 53 per cent and the increase in plasma homocysteine
after methionine loading was reduced by a mean 39 per cent, suggesting
that the impaired metabolism can be improved easily and without
side effects". Vitamin B12 works with folic acid in converting
homocysteine to methionine. Mild vitamin B12 deficiency can be
the result of a poor vegetarian or vegan diet, but can also be
the result of impaired absorption of the vitamin in older people.
Vitamin B12 deficiency, even without deficiency symptoms, is frequently
associated with raised homocysteine levels, that return to normal
with B12 supplementation.
Arthritis takes many forms, but by far the most
common is osteoarthritis—a disease that mostly (but not
exclusively) afflicts the elderly. Many individuals who suffer
from this form of arthritis complain of pain and stiffness of
the neck, back, knees, elbows and fingers. While most people assume
that arthritis is a natural consequence of advancing age, age
is just one contributing factor. A lifetime of wear and tear takes
its toll on vulnerable parts of the body where bone meets bone,
but arthritis does not occur without an abnormal chemical environment
in the joints. Doctors treat inflammatory arthritis with a class
of drugs known as non-steroidal, anti-inflammatory (NSAIDs). Although
NSAIDs are reasonably effective in relieving joint pain, they
do nothing to stimulate the healing pathways, and can produce
side effects such as ulcers, stomach upset, dizziness and headaches—leading
to further illness. The strongest, most effective, natural anti-inflammatory
agent is fish oil, which exerts the same enzyme blocking effects
as NSAIDs. Foods from the sea, rich in certain fatty acids such
as omega-3 fatty acids, eicosapentaenoic acid (EPA) and docosahexaenoic
acid (DHA), have been shown to be extremely beneficial for anyone
suffering from inflammatory types of arthritis. Eating these fats
3-5 times a week, or taking a higher dose fish oil supplement
is likely to reduce the body's overall inflammation levels, thin
the blood and reduce the risk of stroke and heart attack, as well
as arthritis.
5. THE DNA-NUTRITION
LINK
In future, the way to prevent age related diseases
might be to prevent damage to DNA. Genes have become the much
sought after keys to understanding why people inevitably grow
old and develop diseases. Although the increasing pace of genetic
research presents us with one discovery after another—the
so-called cancer gene, the Alzheimer's gene, the obesity gene
and countless others—it seems that in their haste to apply
this knowledge in gene therapy, many researchers overlook simpler
and more practical ways to keep genes healthy and lower the risk
of disease. Vitamins, minerals and other nutrients play an integral
role in how body cells synthesise and repair genes. Research clearly
shows that vitamin supplements can enhance the performance of
genes and protect them from damage.
Genes, built from microscopic double strands
of DNA direct the behaviour of the body's 60 trillion cells. They
define the body's physical features, such as the colour of our
eyes and hair, but they also determine how efficiently the body
works on the inside. When the genes work well, they enable the
body to live to a good age with a low risk of disease. When genes
don't work well, they can accelerate the body's ageing process
and increase the risk for cancer and other life threatening diseases.
The remarkable activity of genes depends on the nutrients provided.
The DNA in the protein we eat is broken down and reconstructed
into the individual's own distinctive DNA. Vitamins B3 and B6
are needed for thymine synthesis, folic acid for guanine and adenine,
and vitamin B3 for cytosine. When these nutrients are lacking
in the body, DNA cannot be synthesised—and its instructions
cannot be carried out. "Diet and genetics interact in numerous
ways to influence chronic disease risk", Gregory D Miller,
PhD, and Susan M Groziak, PhD, wrote in the Journal of the
American College of Nutrition (1997,16:293-295) "Genetics
influence the absorption, excretion and metabolism of all nutrients.
Genetics also influence the human body's physiological response
to diet. Diet, in turn, may influence the expression (activation)
of genes that are related to specific chronic diseases".
DNA is easily mutated or damaged and as DNA
accumulates damage, the likelihood of developing age related illnesses
increases. Research has shown that breaks in single strand DNA
can usually be repaired. However, folic acid deficiency substantially
increases the risk of double strand breaks which are not easily
repaired and may result in permanent damage to DNA.
6. RDAS AND
SCREENING FOR
MALNUTRITION
"Nutritional status surveys of the elderly
have shown a low-to-moderate prevalence of straightforward nutrient
deficiencies, but a marked increase in the role of malnutrition
and the evidence of sub-clinical deficiencies. Recognising the
changes in nutrient requirements with age, and the selection of
healthy, nutrient-dense foods by older adults can contribute significantly
to their adding more life to their years". (Dr Jeffrey Blumberg,
Human Nutrition Research Centre on Ageing, 1998).
A new approach to nutrition is needed and there
is an urgent requirement for a review of RDAs. RDAs were developed
by the Americans in 1941 to protect soldiers from nutritional
deficiencies. Since then, there has been an explosion of knowledge
about nutrients and a review is long overdue. In recent years,
researchers have begun to discover distinct and substantial differences
of the elderly's nutritional needs. Their physiological status
and overall health tend to differ from younger adults. It is unfortunate
that in dietary guidelines, these two groups have been banded
together in one broad classification, as if their dietary requirements
are the same—which they are not. Recent scientific studies
indicate that, to meet the needs of the elderly, the current RDAs
may be too low for many nutrients, and too high for a few. The
RDAs should be used not only to prevent nutritional deficiencies,
but also to reduce major chronic diseases, such as osteoporosis
in the elderly. Reduced energy needs in ageing result from the
decline in functioning of the metabolic rate, and the curtailment
of physical activity. At the same time, there is an increased
need for some essential nutrients, so the diet of the elderly
needs to be nutrient dense. There is a wealth of scientific data
confirming that higher range doses of vitamins and minerals are
necessary to achieve optimum health.
The nutritional requirements of the elderly
should not be based on the false assumptions of the past. This
group deserves detailed research into its actual needs, and it
is likely that nutritional needs may differ between the elderly
and very elderly. It is clear that nutritional intervention could
lead to a reduction in illness and suffering—this is what
preventive medicine is all about.
Malnutrition in the elderly can result from
a number of different causes. Simple problems such as gum disease
or poorly fitting dentures can reduce the total food intake, with
inadequate intake of nutrient dense and fibrous foods. Multiple
health problems are common with ageing, and many elderly are using
numerous prescribed medications. As the number of prescribed medications
increase, the risks increase for drug/nutrient interaction that
interfere with nutrient absorption. Prescribed diuretics can cause
urinary losses for the essential minerals potassium, magnesium,
zinc and copper. Some drugs reduce intestinal absorption, and
drugs such as aspirin (acetylsalicylic acid) prevent vitamin C
absorption.
Lifestyle factors, such as lack of transport
may hinder food shopping, and low income may limit the purchase
of nutrient rich foods. Those who live alone or are isolated may
lack the incentive to either plan or prepare nutritious meals,
and preparation may be difficult due to disabilities such as arthritis
or poor vision. Impaired mental ability, confusion and depression
are all-important risk factors for malnutrition—and not
just for those living in their own homes.
Multiple nutrient deficiencies and protein-calorie
malnutrition are prevalent among the elderly in retirement homes
and in other long term care facilities.
Lack of funding and other financial constraints
should not be deciding factors in extending quality life. What
is needed as a matter of urgency is a nation-wide screening programme
to identify nutritional deficiencies in the elderly. Those entering
hospital should be screened within 24 hours of admission to help
identify those who are malnourished, so that food intake can be
monitored and assistance given to help them select and eat food.
Those in residential retirement homes and other care facilities
should be routinely checked every few years, with dietary counselling
and supplement advice given. It should become the responsibility
of those in charge of the elderly in care to ensure that they
receive adequate nutrients to maintain good health and wellbeing.
Elderly people living in their own homes could be routinely screened
at their GP's surgery, with the same supplement advice and dietary
counselling given. This should be the responsibility of Government,
not regional Health Services. Everyone is entitled to have a long
and healthy life, free from pain and sickness—good nutrition
could safeguard that.
7. FUNDING OF
RESEARCH INTO
THE BENEFITS
OF NUTRITION
IN PREVENTING
MAJOR ILLNESSES
The costs of ensuring that the elderly population
consume diets that are nutrient rich would be minuscule compared
to the costs of orthodox medical care. Providing nutritional supplementation
to the most vulnerable would also be demonstrably cost effective.
The savings to the NHS for cancer and heart disease treatment
alone would be around £5 billion per year. (Governments own
figures DoH, Our Healthier Nation, 1998). What is required
is greater Government funded research into the nutritional influences
on illness, and a willingness to act on its findings.
Nutritional science has developed substantially
world-wide in the past 30 years, and so have the clinical applications
for nutrients. In fact, nutrients in very large doses are provided
as pharmacological agents for some illnesses. Unfortunately, early
work in this area has drawn strong criticism due to the premature
advocacy of certain nutritional treatments allied to the lack
of adequate scientific validation. There are still gaps in our
knowledge, but in the last ten years, scientific justification
for a wider definition of clinical nutrition has been considerably
strengthened, and laboratory tests can now provide evidence of
inadequate nutrition, despite the lack of clinical findings of
classical nutritional deficiency signs and symptoms. It is now
well established that nutritional factors are of major importance
in the development of both heart disease and cancer, the two leading
causes of death in the Western world, and scientific studies validating
their importance in the development of many other diseases continue
to be published.
8. THREATS TO
DIETARY SUPPLEMENTS
AVAILABILITY
At present, in the United Kingdom, vitamin and
mineral supplements are sold under food law. They may be sold
at high potency provided that they pose no threat to consumer
safety and that no inappropriate medical claims are made about
them. CHC very much supports this position, although we would
like to see more information provided to consumers. However, in
many other European countries, such supplements are only available
at much lower potencies up to limits defined by the outdated concepts
of "nutritional need" (RDA's) which are based on an
estimate of the minimum amounts of nutrients needs to avoid deficiency
disease like beriberi and scurvy—thus completely ignoring
the potential benefits of higher potency supplementation.
The European Union is currently preparing a
Draft Directive on Vitamin and Mineral Supplements. The Directive
has been awaited for a number of years, and it is expected to
be published in the very near future. The Directive will seek
to harmonise the law in EU Member States in respect of the sale
of vitamin and mineral supplements.
Many countries across Europe currently only
allow the free sale of such supplements in potencies related to
the RDAs (see above), or lower multiples thereof. If such an approach
was accepted as the basis for the legislation, then this could
lead to a situation in which many safe, higher potency supplements
were banned both in the UK and across Europe. In reality, consumers
who have been enjoying the benefits of higher range supplements
for a number of years would not stop buying them—they would
find an alternative source of supply. Mail order and Internet
purchasing of such products would increase, and safety could be
undermined.
The United Kingdom continues to argue in Europe
that legislation should be harmonised in such a way that it allows
for both the continued sale in the UK of safe, higher potency
supplements, and also extends to the rest of Europe the opportunity
for consumers to have access to such safe supplements of their
choice. We are most anxious that the UK Government should maintain
this position in the discussions which now lie ahead, and so avoid
the threat that harmonisation of legislation could lead to a ban
in the UK on the sale of safe and popular higher potency supplements.
The pharmaceutical lobby in both France and Germany is very strong,
and they seem determined to secure legislation based on one or
three times the RDA.
We greatly appreciate this policy position on
behalf of the Government and hope that your Committee will feel
able to endorse it, whilst positively encouraging further research
into the effects of dietary supplementation in improving and extending
quality of life.
January 2000
|
