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Letters to the Editor Issue 106

by Letters(more info)

listed in letters to the editor, originally published in issue 106 - December 2004

Jane Jones, Campaign Director, National Pure Water Association 1938 – 2004

Jane Jones, campaign director, NPWA, died from cancer on Friday September 3rd, 2004.

For ten years as campaign director for the NPWA, Jane waged war on those who would attempt to violate the basic human right of every individual to refuse medication or treatment via fluoridation of the drinking water. She continued to work over the past six months while in pain and weakened by the cancer. Only three weeks before her death, did Jane reluctantly lay down her sword as she could fight on no more. She did her last radio interview from home in the geranium garden she dearly loved.

While Jane was, and always will be, remembered for her relentless battle against fluoridation, to her it was symbolic of much broader issues – about HUMAN DIGNITY, HUMAN RIGHTS and JUSTICE for all people.

For the many thousands of people Jane touched across the past ten years, as the campaign director for the NPWA, she will be remembered for her fearless tenacity in facing the most powerful adversaries and showing limitless compassion to those in need.

Jane's presence will be missed by all who knew her, but her legacy will be carried on by all who listened to her words.

Jane Jones is survived by her husband, two daughters, a son, and two grandchildren. Her funeral memorial service was held in Whiston, South Yorkshire on September 14th. By coincidence, Whiston was the last place that Jane spoke publicly!

For those wishing to send flowers, Jane would wish that the money go to the Park Attwood Clinic. A fund has been set up to purchase a reverse osmosis system as the area is fluoridated.

 

The Jane Jones Fund
c/o Park Attwood Clinic, Trimpley Lane, Bewdley, Worcestershire DY12 1RE

Further Information
info@npwa.freeserve.co.uk
Contacts
Peter Crampton, West Yorkshire Against Fluoridation, Tel: 01422 884451
judithcrampton@onetel.com
John Graham, NPWA, London, Tel: 020 8597 5868
jfg@jfgraham.fsnet.co.uk
Sue King, Fluoride Exposure Network, Tel: 01455 822289
kings1955@aol.com & eml.ltd@virgin.net
Liz Vaughan, UK Councils Against Fluoridation, Tel: 01229 885420
liz@vaughan200.fsnet.co.uk

Lavender Essential Oil Production in Devon

I have just found the article: Integrity of Essential Oils by Dr Akash Chopra and Julian Franklin (Positive Health Issue 55 August 2000) and am fascinated because I have planted out 4 acres of Lavandula angustifolia for oil production in Devon. I am in the process of building a steam distillation unit on site, so if anyone is in doubt about the oil that they are buying they can come and look at the plants as they are harvested, watch as it is distilled and take away pure English angustifolia oil knowing exactly where it came from.

There will be oil to bottle from this time next year for those who are interested in our venture. I hope that what we are doing will help to encourage retailers to demand to know the origin of their oils; however, I fear that money and ignorance will limit us to a specialist market We have recently set up a website www.devonlavender.com should you wish to visit us.

Jonathan Watts
jonathanwatts@hotmail.com www.devonlavender.com

Nutrition and HIV: Losing Rights to Choose Dietary Supplements!

by Bradford McIntyre

Are you aware you're losing your rights to choose? Have you noticed your choices of natural health products for optimizing your health are disappearing?

Why? Because of legislation passed by European Union (EU) Directive on Dietary Supplements and the fact that other countries are bound to the rules and laws of the World Trade Organization.

In the early years of the HIV and AIDS epidemic, there was no treatment. I was witness to and learned from people who were using vitamins, minerals, herbs and botanical supplements to combat illness and/or boost their immune system. When the pharmaceutical drug AZT was first introduced as a treatment for HIV and AIDS, instead I chose vitamin supplements as a means to boost my immune system and stay healthy. I did not take HIV/AIDS medications for 13 years, out of the 20 years I have been infected!

It wasn't until 1997 that I first realized the threat the Codex Alimentarius posed. Throughout the years I have watched closely, signed petitions and written to the Canadian government expressing my opposition to the German delegation's proposal to the World Health Organization's Codex Alimentarius, the Committee on Nutrition and Foods for Special Dietary Uses.

I believed then, as I do now, that if regulations are put into place, my rights as a consumer of nutritional supplements will be jeopardized. Dietary supplements which promote my well-being will become more costly and harder to obtain, and no supplements will be available for therapeutic or preventative uses without prescriptions. Dosages will have minimal amounts with higher costs!

• By August of 2005, 5,000 products will disappear?
• An imminent threat of being robbed of the right to choose!
• Fight to keep our supplements!

We are not only ill-informed but governments around the world are making these deliberate legislative decisions without informing the general public! The mainstream media as well has avoided coverage of this legislation!

That being said, you can look to the Internet for all the details on how this legislation has been taking place, and get involved!

Bradford McIntyre, HIV+ 20 years, Vancouver, Canada
bradmcin@telus.net www.PositivelyPositive.ca

Further Information Codex Alimentarius
www.codexalimentarius.net/web/index_en.jsp
European Union Directive on Dietary Supplements and Codex Alimentarius legislation:
International Advocates for Health Freedom: www.iahf.com
American Holistic Health Association www.ahha.org
Alliance for Natural Health www.alliance-natural-health.org

Alternative Medicine Free on the NHS

The Prince of Wales's Foundation for Integrated Health was featured in the Daily Telegraph in October, which reported the new Patient's Guide that the Foundation will be distributing to all GP surgeries in December, describing "a list of free therapies including osteopathy, acupuncture, aromatherapy and homeopathy.

This guide has been funded by the Department of Health and its purpose is to promote integrated healthcare and to give both patients and GPs information about 15 of the most common therapies, including aromatherapy. It does not however give people access to free therapy session unless the GP practice wishes to fund it.

The article was quite mis-leading as it stated that "The Department of Health confirmed that patients could now ask their GP to refer them, free of charge, to practitioners of any of the therapies".

The Aromatherapy Consortium (AC) office contacted the Department of Health and was given the following statement:

"Provision of Complementary and Alternative Medicine (CAM) on the NHS – The Government expects decisions on local services to be made by front-line service providers, and this also applies to complementary therapies. In making such decisions, NHS organisations take into account evidence for the safety and effectiveness of the treatment, and the availability of properly qualified and regulated practitioners. A patient can discuss their needs with his or her general practitioner who will then make a clinical decision as to the type of therapy or treatment appropriate for the patient's condition."

So there is no new initiative on CAM by the Department, but this Patient's Guide does go some way to helping get the message across. GPs will only want to refer their patients to properly qualified and regulated aromatherapists, and that is why our work is so vital and your support by registering yourself so important.

The PoWFIH Patient's Guide will be available to purchase from their offices for £5.99 (Tel: 020 7619 6140) when it is published and be available as a PDF from their website at www.fihealth.org.uk

Carole Preen,
SecretaryAromatherapy Consortium
info@aromatherapy-regulation.org.uk

 

Codex Update

With the Dietary Supplements Guideline safely in hand, attention has now turned to the process of setting maximum upper safe limits. This will undoubtedly involve some consideration of nutrient reference values (NRVs). South Africa has been chairing an electronic NRV working group for the past year and presented its findings at these year's meeting. After delivering their preliminary report, South Africa recommended that further work be done by the group to:

1. Establish the scientific basis upon which new/revised NRVs can be established;
2. Determine the range of nutrients to be included and the criteria for their selection;
3. Determine the number and age boundaries of population subgroups for which NRVs should be established and the criteria by which these decision should be made.

South Africa, in reference to point two, presented a list of nutrients that included essential fatty acids and the carotenoids lutein and lycopene.

The EU took exception to the list, which included nutrients other than vitamins and minerals. After some debate, the EU got its way but did agree to allow South Africa to continue its work. This will require some heavy lifting, and South Africa appealed to its committee members to provide the data they will need to finish their work. It is hoped that they will get the data they will need to make a credible report since these numbers will be crucial in assuring that proper limits are set. We should use whatever contacts we have to ensure this happens.

In a related matter, WHO reported that they will be convening a work shop on risk assessment for nutrients within the next year. WHO is looking for experts to provide data and this is a perfect opportunity for individuals such as Bob Reynolds (Vitamin B6) to present their data. I suggest we consider sponsoring some individuals of his calibre to make their case. This is a strategy we discussed at our last meeting that could have a significant outcome on WHO's outcome. Codex defers to WHO and FAO on many matters and this might be the leverage we need to tip the scale in our favour.

Also noteworthy at today's meeting, the Codex committee included draft language for baby formula that would prohibit irradiation as a means of sterilization. There was also significant support to prohibit the use of GE soy in non-milk formulas and to exclude partially or fully hydrogenated oils.

James Roza, Now Foods
Source:
Elwood Richard,
President Now Foods
elwood.richard@nowfoods.com

EU Regulatory Proposal for Nutrition and Health Claims On Foods

It is well known that there are numerous misuses of claims in the marketing of foods within the food sector, where foods that are patently unhealthy are presented as 'healthy' to the consumer. At a time when disease arising from poor diet is at epidemic proportions, particularly in the areas of cardiovascular disease, obesity and diabetes, some further controls are clearly needed if the tide of diet related disease is to be turned – and the EU Parliament has requested that a new Regulation should be introduced to bring some much needed controls in this area and harmonise legislation across the EU.

As a result, a proposal has been drawn up and is currently under discussion. This regulatory proposal has four clearly stated aims.

1. That health claims made on foods should be capable of being substantiated and true (already provided for under existing legislation) and therefore not mislead the consumer;
2. That unhealthy foods should not be able to make health claims i.e. a food unhealthily high in certain nutrient forms should be prohibited from making a health claim;
3. That provision should be made to permit, where the evidence exists, disease risk reduction claims;
4. That the regulation should facilitate greater EU market harmonization and remove barriers to trade arising from differing Member State legislation in this area.

In broad terms, such aims are greatly supported by Practitioners, industry and consumers alike, and few people or organisations (if any) have substantial objections to these stated aims. The provision to make certain disease risk reduction claims are particularly welcome. As anyone with any nutritional knowledge is aware, a correct and balanced diet at both 'macro' and 'micro' nutrient level, can and does reduce both the risks, incidence and in some cases course and progression of disease. Since the law states that foods may not be presented with a view to treating, curing or presenting disease, this provision to allow disease risk reduction claims is a major step forward.

The Problems

As is often the case in legislation, the 'devil is in the detail' of the proposal. A number of provisions within the text cannot be in the public interest and in fact will work in direct contravention to many of the stated Government policy aims with respect to consumer information and the interests of consumer health and self-treatment. Furthermore, there are substantial issues related to issues of freedom of speech and freedom of information.

Whilst this piece of legislation may not seem of enormous interest to Practitioners at first glance, it has to be remembered that all Practitioners are in the business of improving the health and well-being of their clients. Many Practitioners in all manner of disciplines may well include nutritional advice and recommendations for food supplements within their daily practice, especially in view of the fact that the micronutrient content of foods is decreasing at an alarming rate and that there is growing evidence of widespread micro-nutrient deficiencies within populations. What is more, there is potential for very dangerous precedents to be set by some aspects of this proposal, that could come back to bite as Alternative and Complementary Therapies become regulated at an EU level.

Products covered

It is intended that the Regulation should apply to all products that are covered by Food Law: That means fresh produce, packaged foods, specialist foods e.g. Organic Health Foods, and Food Supplements.

Persons and Organisations Covered

The Regulation will apply to manufacturers, suppliers, and distributors and retailers of foods, whether for financial gain or not, and will apply to all commercial communications, including 'generic' non specific information. If a Practitioner 'sells on' any specialist food or supplement, it will therefore apply directly to them and any literature they produce to further the sales of that food.

It will NOT apply to dietary guidelines or advice issued by public health authorities and bodies, or communication and information by third parties such as the press and scientific publications.

Nutrient Function Claims

Under EU Napoleonic Law, only that which has been positively provided for in legislation is legal – everything else is illegal. The wording of the Regulation envisages that a generic, 'positive list' will be developed for nutrient – function claims, listing in precise word form all the types of claim that will be permitted, in exact detail. Anything else will be required to go through the European Food Safety Authority (EFSA) for approval.

For a nutrient function claim to be included in the generic list the proposal requires the claim to be substantiated by 'well-established science'. Based on the recent UK Food Standards Authority and Joint Health Claims Initiative project which looked at a UK list of generic claims for Vitamins and Minerals, data needs to be:

1. Consistently reported in textbooks;
2. Have a plausible and defined mechanism of action;
3. Have no conflicting data or scientific disagreement;
4. Only look at data from studies in 'normal' population groups.

Applying these rules, a claim that 'Vitamin C supports the Immune system' would not be permitted and nor would any claim for the role of Chromium in blood sugar regulation and thereby appetite management, among others. Both of these claims would be banned in any event under the provisions of Article 11 (see later).

Incredibly, evidence based on the latest science would be excluded from consideration and communication – whether positive or negative. This has serious potential impacts on the role that industry plays in ongoing Practitioner and consumer education, and could result in potentially life changing, life saving, or life threatening information being withheld from consumers for some years until the information found its way into textbooks. This cannot be in the consumer's best interests.

Banned Claims

On the basis that claims could 'mislead' or 'not be easily understood' Article 11 provides for banning certain claims even if true. This presents serious issues with relation to freedom of speech and information, and would result in information being withheld from the consumers in nutrition related disease priority areas.

Proposal for banned claims are:

1. General claims on the basis that they are 'woolly and misleading'. On this basis a claim would not be able to be made for a multivitamin as supporting general health, nor could companies repeat the UK Governments '5 a day' health messages in educational or promotional materials. Furthermore claims for supplements to support 'immune system health', 'cardiovascular health' and so forth would fall into this category.
2. Weight loss claims including references or indications to slimming, slimness-promoting, weight-reducing, weight-controlling properties, reductions in the sense of hunger, or increase in the sense of satiety or to the reduction of the available energy from the diet are to be banned outright. Given the current issues with obesity, it is incomprehensible why this provision has been made to ban these claims outright, if such claims can be proven and scientifically substantiated. This Article would ban, for example, communication of the benefits of low glycaemic index foods and their relationship to weight loss.
3. Claims relating to psychological and behavioural function. It is well known and evidenced that food can affect mood and behaviour, from evidence that excess caffeine causes irritability to the role of Omega 3 EFA intakes in relation to neural function and mood.

Additionally, the following claims are to be prohibited, which are understandable but in some circumstances may be counter productive e.g. cases where dissemination of the dietary recommendations of specific groups such as the British Heart Foundation, or the National Osteoporosis Society may be beneficial for consumer education.

1. Claims which make reference to recommendations or medical opinions of doctors or case histories;
2. Claims which make reference to members of the medical, therapeutic or pharmaceutical professions or their professional associations or charities;

Impacts

The impacts to the commercial sector are potentially severe. The vast majority of supplement and specialist food manufacturers, producers, suppliers and distributors will be entirely unable to comply with the approval requirements proposed – even where adequate evidence exists to make valid claims. Over 90% of food business' have less than 10 employees; the workload such a Regulation would produce would be impossible for small organisations to accommodate and remain profitable and in business.

Many specialist niche products with low turnover will be withdrawn, reducing consumer choice and product availability. For Practitioners using or recommending supplements or specialist foods as part of their daily practice to improve the health and well-being of clients, this must be of great concern.

Advertising revenues of specialist media titles will be severely affected as product advertising may be affected. Whether you like adverts or hate them in your Practitioner Journals, the commercial reality is that magazines need such revenues to remain viable.

The educational resource of corporate updates and research news is likely to cease, as the Regulation will also apply to generic information. Professional Associations need to determine how much reliance is placed on commercial updates to aid ongoing Practitioner Education. Some slack can be taken up by professional journals in this regard. This assumes that the Journals will have been able to survive the losses of advertising revenues – at the very least subscription costs would have to rise dramatically.

Of the greatest concern is the blanket bans proposed by Article 11 on slimming and weight loss, behavioural, psychological and general claims, and overall the potential effects on consumer education. Perhaps of greatest concern is the precedents such a ban would set. The rationale for banning these claims, based on the consideration that consumers may not fully understand a claim in one sentence, that the issues are complicated, and that the consumer could therefore be misled. It is not a great conceptual leap to a world where health claims for CAM practices could be similarly banned for similar reasons at some point in the future.

Summary

This Regulation has been designed to control the claims made on processed foods, rather than specialist foods and supplements. It is the claims made by processed food producers that have resulted in the majority of health claims issues, and some unscrupulous suppliers of specialist products over the Internet. However, the fact remains that legislation already exists to control this situation and the problems arise through a lack of enforcement. This Regulation will face similar issues if the quality of enforcement is not improved whilst removing much valuable information that links nutrition to health.

However, it must be accepted that the Regulators are seeking to improve our health through diet, and their intent has been good. The issues are real and they do need to be addressed. However, the issues with respect to specialist dietary foods and supplements have simply not been thought through adequately, the contribution that industry makes to health education has not been adequately recognized, and the ability of small organisations to comply with such a Regulation has not been considered thoroughly enough by EU Regulators.

Therefore, some modifications are needed – and the simplest solution would be to exclude supplements on the basis that these have already been legislated for in the Food Supplements Directive. However, this won't help other specialist health food producers and organic farmers, so the Regulation wording itself needs change no matter which way it is looked at.

The Regulation is still in its formative stages having been successfully delayed before the EU elections in May, so there is still time to write to the UK Food Standards Agency, your MP, your MEP and your Professional Associations to make your views heard and to get the proposal changed into a more workable form. Article 11 and its rationale for banning claims even when true must be challenged vigorously.

The changes required to the proposal are relatively simple.

1. Delete Article 11 with respect to banned health claims. All claims that can be proven should be permitted;
2. Simplify the approval mechanisms for claims, so that it is achievable for small business and especially small specialist health food producers, distributors and retailers. Especially remove the requirement for all claims and all commercial materials in all languages to be approved, which would be administratively and financially crippling;
3. Remove nutrient function claims from the proposals for European Food Safety Authority (EFSA) pre-approval, but define clear levels of scientific substantiation required for these claims to be used as well as generic, non product specific information that may be communicated without further reference to EFSA;
4. Provide a clear derogation for all health professionals belonging to registered trade bodies with respect to health and dietary information, so that they may continue to provide their clients or patients with relevant and beneficial health and dietary information where appropriate. Whilst it is not intended for Practitioner Advice to be included, there is a degree of legal uncertainty that is best removed from the current proposal.
5. Ensure that scientific substantiation is based on a balance of evidence, so that the latest science can be considered. This would ensure that studies that look at specific population groups with illness would then be able to be used as part of the evidence package, even though any claim that would imply treatment cure or prevention of disease would still be prohibited.

Please Act Now!

The plea is to ask every individual who is concerned about protecting CAM therapies and their freedom of access to health and nutritional information to please register their protest and dissent to those aspects readers find themselves in agreement with.

Source
Isobel Bradley, Administrator Alliance for Natural Health Info@alliance-natural-health.org

Further Information

Find your local MP and MEP at the Alliance for Natural Health website: www.alliance-natural-health.org

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