OCA Nutri-con Campaign Full of Errors

Dear OCA (Organic Consumers Association), I am personally concerned about the misleading and inaccurate statements made regarding the OCA’s Nutri-Con program (http://organicconsumers.org/nutricon.cfm). The lack of accurate scientifically valid information and the application of misleading science within inappropriate examples will only serve to put the whole program in a questionable light. Don’t get me wrong, it is preferable to get nutrients from food. But as government studies have shown that up to 95% of the public suffer from deficiencies below RDA levels of vitamins and minerals (not the 99% stated in your article), it is important to have a cost-effective and simple means to correct nutrient deficiencies and enhance healthy homeostasis. Ten of thousands of scientific studies have shown that the common forms of nutrients used in today’s dietary supplements are safe, suitable and effective for this purpose. Your web page seems to promote specific brands, which calls the integrity of the information into question. For example, Neo-Life is touted as good and other brands seem to be bad. You post an article taking us to a commercial webpage (http://www.nutriteam.com/natural.htm) Why are explicit commercial endorsements being made? Here are some specific problems with the accuracy of the information: Synthetic vitamins: This term is misleading unless you are speaking about vitamins with separate natural and synthetic forms, like alpha tocopherol (vitamin E). For most other vitamins the term is meaningless because most synthesized B vitamins (many are actually naturally grown by a fermentation process) are identical to the forms found in food. This is called a natural form or a nature-identical form. When a vitamin is synthesized, it is not called a synthetic form unless it is chemically/structurally different from the natural form. You will only cause confusion if you refuse to follow this important distinction that is essential to a common understanding of chemistry and biology. You simply should not just make up terms for nutrient forms that are confusing to scientists and laypersons alike. Your terminology should be true and accurate and not likely to confuse the reader; but so far, I fear that you have failed to accomplish this. The author claims that “synthetic” vitamins cause disease. Please provide some real proof. I have read hundreds of studies to the contrary and toxicology records also indicate a good margin of safety for conventional vitamins. To claim that a synthesized nature-identical B vitamin produced by fermentation will provoke the same immune reaction as an invasive organism is simply incredible (as in not credible). He also claims, “Certain studies on natural vs. synthetic vitamins have shown that synthetic vitamins are 50 to 70% less biologically active than natural vitamins,” without making it obvious that he is only referring to vitamin E, which is the only one that has a “dl” form, not to other vitamins. I see it as intellectually dishonest to falsely imply that all synthesized vitamins share this problem. Regarding beta carotene: Your statement: “It's no wonder that some of the testing done with the synthetic form of beta-carotene has produced mixed results, and in one study on smokers, produced a negative result.” In fact, the problems with beta carotene were largely the result of other confounding factors and poor science, not the synthetic production of the nature-identical pro-vitamin. I certainly prefer the complexes to the isolates, but the fact is that the beta carotene molecule itself is the same exact form and molecule, whether produced from food or by synthesis. It is actually the presence or absence of total antioxidants that is the determining factor for people’s health in these studies. Some years ago an antioxidant study in Finland was halted early because of a widely reported increase in cancer rates among male smokers taking beta-carotene. (1) Headlines associated this supplement with cancer risk. Despite objections that the study was flawed, beta-carotene use dropped. A later analysis published in July 2004 took another look at that exact same Finnish smokers' study data, but now taking into account total antioxidant intake, which cleared away the scientific controversy. The smokers’ risk of getting lung cancer was inversely associated with total antioxidants in the diet, with more total antioxidants meaning fewer cancers. (2) A composite antioxidant index was generated for each of the 27,000 men over 14 years. The calculated amounts of carotenoids, flavonoids, Vitamin E, selenium and Vitamin C were compared to actual lung cancer rates, with a clear result: the combination of antioxidants lowered lung cancer risk in male smokers. Another large study has noted that high beta carotene intake, confirmed by measures of blood levels, was associated with lower mortality rates among the elderly over a ten year period. (3) The dietary level of antioxidants is an independent predictor of plasma beta-carotene, especially in moderate alcohol drinkers. A more recent study reports, “This may explain, at least in part, the inverse relationship observed between plasma beta-carotene and risk of chronic diseases associated to high levels of oxidative stress (i.e., diabetes and CVD), as well as the failure of beta-carotene supplements alone in reducing such risk.” (4) Still, news reports continue to refer to beta-carotene as harmful, largely because of the original study reports. The “media myth” continues long after the science has moved on. Nutra-con seems to have bought into the myth. The same beta-carotene molecule is produced either synthetically or as a food extract, with the exact same optical rotation and measured by the exact same blood tests. Beta Carotene REFERENCES: 1. The Alpha-Tocopherol, Beta Carotene Cancer Prevention Study Group. The effect of vitamin E and beta carotene on the incidence of lung cancer and other cancers in male smokers. N Engl J Med. 1994 Apr 14;330(15):1029-35. http://content.nejm.org/cgi/content/full/330/15/1029?ijkey=bd47b716724d0dad4cad0fb19337308753658337 2. Wright ME, et al. Development of a Comprehensive Dietary Antioxidant Index and Application to Lung Cancer Risk in a Cohort of Male Smokers. July 2004 American Journal of Epidemiology http://aje.oupjournals.org/cgi/content/abstract/160/1/68?maxtoshow=&HITS=10&hits=10&RESULTFORMAT=1&andorexacttitle=and&andorexacttitleabs=and&fulltext=beta+carotene&andorexactfulltext=and&searchid=1100534768534_1530&stored_search=&FIRSTINDEX=0&sortspec=relevance&fdate=7/1/2004&tdate=7/31/2004&journalcode=amjepid 3. Buijsse B, et al. Plasma carotene and alpha-tocopherol in relation to 10-y all-cause and cause-specific mortality in European elderly: The Survey in Europe on Nutrition and the Elderly, a Concerted Action (SENECA). Am J Clin Nutr 2005;82:879–886. 4. Brighenti F. The total antioxidant capacity of the diet is an independent predictor of plasma beta-carotene. European Journal of Clinical Nutrition (2007) 61, 69–76. doi:10.1038/sj.ejcn.1602485; published online 12 July 2006. Supported by the European Community IST-2001–33204 'Healthy Market', the Italian Ministry of University and Research COFIN 2001 and the National Research Council CU01.00923.CT26 research projects. Regarding “Biological Activity Reduced 50%”: This is certainly true for vitamin E, but your website inaccurately implies that this is true for many other vitamins. In fact, it is only true for vitamin E, but it is also true that some vitamins and minerals are absorbed better from dietary supplements than from food. This is the case for non-heme iron from plant sources, which is poorly absorbed, while chelated iron supplements are relatively well absorbed. This is also the case for folic acid, which is demonstrably less well absorbed from food than from supplementation. REFERENCES Heme iron is absorbed better than nonheme iron, but most dietary iron is nonheme iron. [8]. Absorption of heme iron ranges from 15% to 35%, and is not significantly affected by diet [15]. In contrast, 2% to 20% of nonheme iron in plant foods such as rice, maize, black beans, soybeans and wheat is absorbed [16]. Nonheme iron absorption is significantly influenced by various food components [1,3,11-15]. Dietary Supplement Fact Sheet: Iron, Office of Dietary Supplements • NIH Clinical Center • National Institutes of Health Bioavailability of food folates is 80% of that of folic acid. RM Winkels, IA Brouwer, E Siebelink, MB Katan, and P Verhoef Am J Clin Nutr 2007 85 (2): p. 465 Regarding Polarized Light and Optical Rotation: The difference is certainly true for Vitamin E, but not at all true for B-Vitamins. Your article has falsely implied that this is true for all “synthetic” vitamins. Finally: This is just a sampling of data - not a complete list of all issues of sloppy or incorrect science - to show that OTC Nutri-con's program is not accurate in:

• Implying that synthesized vitamins are all synthetic forms
• Stating that all natural source supplements are better utilized than all synthesized nature-identical materials
• Stating that synthesized material is less safe than natural material (in fact, the micro contamination from natural materials far exceeds that of synthesized ingredients)

OCA is not uniquely qualified to pass judgment on these matters after having produced such mixed-up nonsense as background material. Nutra-con seems to be a con job, in my opinion. I support OCA and do not understand why it would embark on a divisive campaign based on such highly questionable science that is so easily proven to be false or misleading. It is also questionable in promoting specific companies as providing better ingredients, even though they may not match the materials used in scientific studies that provide components that the public wants to use, in light of their proven safety and efficacy. Please allow me to ask you to reconsider your program, in the interest of truth in science. Your organization’s credibility will be challenged by the scientific community and will justifiably suffer if you proceed on this erroneous course of action in a field so far removed from your experience and expertise. This could be disastrous for OCA if all of your positions are dismissed by many people because of one seriously flawed program that could harm your reputation for integrity and scientific accuracy. It is one thing to promote naturally occurring nutrients from food sources, which is fine if the science is accurately presented. It is quite another to promote specific brands with poor scientific justification, as you seem to already be doing. This is just one man’s opinion, but I would hate to see OCA be isolated by pushing an untrue Truth campaign. I have spent a good part of my adult life defending the natural products industry, but there is no good defense for a misguided effort that misfires and winds up “shooting you in the foot”. Neil E. Levin, CCN, DANLA Certified clinical nutritionist with diplomate in advanced nutritional laboratory assessment Author of - or contributor to - many articles defending natural products:

• Say No To GMOs
• Bittter Harvest
• Benefits of herbs
• Cancer patients may very well tolerate the use of certain dietary supplements (CA: The Journal of the American Cancer Society)
• Childhood Obesity (Vitamin Retailer magazine)
• Europe Biotech
• FDA Scientists Report Political Interference in Their Work
• Green Foods (Whole Foods magazine)
• Grocery Headquarters: Biotechnology still hasn’t lived up to its promises
• LAND OF CONFUSION: HOW POOR SCIENCE AND MISLEADING MEDIA COVERAGE CREATE PUBLIC CONFUSION ABOUT HOW DIETARY SUPPLEMENTS AFFECT HEALTH (Journal of Applied Nutrition)
• Modified foods, modified truth
• More evidence of vitamin E safety!
• No appetite for biotech foods
• Organic Spices (Organic Products Retailer magazine)
• Raw Deal on Vitamins (Organic Style rebuttal)
• Reducing Healthcare Costs Naturally
• Sweeteners (Whole Foods magazine)
• The Case for Multiple Vitamins
• Who’s Afraid of GMO’s? –Me!

Neil E. Levin, CCN, DANLA Board Certified Clinical Nutritionist with Diplomate in Advanced Nutritional Laboratory Assessment www.honestnutrition.com