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Editorial Issue 138

by Sandra Goodman PhD(more info)

listed in editorial, originally published in issue 138 - August 2007

Am I a naïve imbecile or what? Just as more detailed research is being published and accumulated regarding the importance of diet and nutrition in disease prevention and treatment, there appears to be a greater effort and focus in closing down health stores and quality and innovative nutritional supplements. Not to mention the increased litigation and prosecution of practitioners who recommend specific nutritional supplements, under the Kafkaesque laws classifying a supplement as a food or a drug.

I am referring to the items in Brief Takes (see page 5) EU to Outlaw Supplements and 50% Health Food Closures, as well as the letter by Byron J Richards US FDA Announces Plan to Eliminate Vitamin Companies, which I implore PH readers to study carefully.

Another similarly worrying communiqué from the Alliance for Natural Health  (, about the FDA Draft Guidance, quotes directly from the Guidance:

“The FDA Guidance speaks in plain language. We all know just how healthy raw vegetable juices are, but we are also aware that when a practitioner deals with a cancer patient, the practitioner is very likely to want them to recommend raw vegetable and fruit juices as part of the recommendations offered. This could get them into a lot of trouble, as suggested by the following quote directly from the Guidance (Docket No. 2006D-0480]:

“If the juice therapy is intended for use as part of a disease treatment regimen instead of for the general wellness, the vegetable juice would also be subject to regulation as a drug under the Act.

“It’s hard to think only of ‘general wellness’ when someone is dying of cancer. A good practitioner tends to be thinking much more about: how do I modulate the immune system? How do I increase serum antioxidant levels? How do I help the patient re-establish effective self-healing mechanisms in the body…

“In short, although it might be easy for products in the retail sector to stick within the structure/function claim constraints of Dietary Supplement Health & Education Act [DSHEA], the most difficult thing for any CAM practitioner is the context in which he or she practises. The FDA has the legal power to say that any practitioner who is seeing patients or clients with serious diseases, and are then providing recommendations, is effectively providing products which are “intended for” the “mitigation, treatment or prevention of disease”. If this were to be the interpretation, any use of dietary supplements by practitioners could be considered illegal. “This is at least as worrying as some of the developments and legal and regulatory interpretations going on in Europe, with which we are very familiar.

“There is however a more hopeful interpretation given on page 12 of the Guidance, where the example of cranberry for urinary tract infections is explored. Fortunately the Guidance implies that the context of the practitioner-patient is probably not sufficient to constitute “intention for disease treatment”, which would otherwise make cranberry products drugs. The Guidance proffers that it is the label claim that is the deciding factor. If you stick within the area of structure/function claims and state on the label “maintains the health of the urinary tract” your product will still remain a dietary supplement. However, should your product carry a claim like “prevent urinary tract infections” you will then have ventured into drug territory.”

This suggests that doctors and nutritionists adopt a manner more like an Agatha Christie detective rather than prescribing as professional health practitioners, referring to their legal scripts and endless bureaucratic regulations instead of concentrating on which foods, nutrients or supplements could help to alleviate the patients’ conditions.

Research from well respected sources such as the Scottish Crop Research Institute (SCRI) has demonstrated (please see Short Feature page 8) that “those fruits with a purple/red colour perform particularly well – the darker the fruit the higher the anthocyanin/antioxidant content. The British blackcurrant has high levels of antioxidants, known as anthocyanins, which can help to prevent Alzheimer’s, heart disease, eye strain, MRSA and urinary tract infections.”

The Cover Story of this issue Colour Coding Your Diet by Lauryn McGuiness describes the many therapeutic effects – including antioxidant, anti-viral, anti-cancer, anti-inflammatory, immune-enhancing, anti-microbial, anti-stress – of the beneficial ingredients contained within a wide range of coloured fruits and vegetables – including lycopene and other carotenoids, isothiocyanates, vitamins C, E, B vitamins, anthocyanins, flavonoids, allicin and pectins. This is reinforced by a description of the benefits of pycnogenol (see page 26).

I would also be remiss if I didn’t strongly commend Roger Coghill’s fascinating and authoritative discussion of Bioresonance (see pages 14-19); Part II in the next issue.

With Natural Healthcare truly going pear-shaped in the Real World, perhaps we will all have to decamp to and set up a truly holistic integrated health system in the Virtual World?


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About Sandra Goodman PhD

Sandra Goodman PhD, Co-founder and Editor of Positive Health, trained as a Molecular Biology scientist in Agricultural Biotechnology in Canada and the US, focusing upon health issues since the 1980s in the UK. Author of 4 books, including Nutrition and Cancer: State-of-the-Art, Vitamin C – The Master Nutrient, Germanium: The Health and Life Enhancer and numerous articles, Dr Goodman was the lead author of the Consensus Document Nutritional and LifeStyle Guidelines for People with Cancer and compiled the Cancer and Nutrition Database for the Bristol Cancer Help Centre in 1993. Dr Goodman is passionate about making available to all people, particularly those with cancer, clinical expertise in Nutrition and Complementary Therapies. Dr Goodman was recently featured as Doctor of the Fortnight in ThinkWellness360.

Dr Goodman and long-term partner Mike Howell seek individuals with vision, resources, and organization to continue and expand the Positive Health PH Online legacy beyond the first 30 years, with facilities for training, to fund alternative cancer research, and promote holistic organizations internationally. Read about Dr Goodman and purchase Nutrition and Cancer: State-of-the-Art.  She may be contacted privately for Research, Lectures and Editorial services via:   and

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