Updated Excerpt from
Codex Alimentarius — The End of Health Freedom
Brandon Turbeville — Activist Post
In past articles, I have written extensively on the dangers of using Risk Assessment when dealing with vitamins and minerals. I have explained how the risk assessment methodology is being used to establish both Upper Safe Levels and Maximum Permitted Levels, as well as demonstrated the connections between Codex Alimentarius and the German Federal Institute for Risk Assessment (BfR). These connections are important because it is BfR that has been contracted by Codex to provide scientific information and advice on nutritional supplements using just this process. In this and subsequent articles, I will examine in more depth the findings presented by BfR and the ramifications they will have for access to vitamin and mineral supplements the world over.
In 2005, BfR published “Use of Vitamins in Foods: Toxicological and nutritional-physiological aspects,” its list of recommendations for the maximum levels of nutrients in vitamin and mineral supplements. Of the many tables included in these results, Tables 3 and 4 are of particular interest. Table 3 is an overview of the BfR teams’ classification of vitamins and minerals into supply and risk categories (each of these categories being separate).
Supply categories deal mainly with the status of the supply of tested materials such as their possible contamination or their potential to be contaminated during shipping as well as the intake status. However, the risk categories have to do with the potential for nutrients and vitamins to cause adverse effects.
The risk category is divided into High risk, Moderate risk, and Low risk, and is based on “how large the margin is between recommended/observed intakes and the defined UL” [Upper Limit].  Rather, how much further than the Recommended Daily Allowance (RDA) a nutrient must go to reach the level of perceived adverse side effects (the Upper Limit). Indeed, Table 2, which is a different chart showing the criteria for each risk category, is entitled “Various degrees of probability that a nutrient leads to adverse side effects.” This in itself should trigger questions as to what amount of “proof” this study actually offers.
The idea that it is the probability, not a clearly defined set of risks or causes of those risks, shows that the study has not actually proven that nutrients pose a threat of adverse side effects, even when using the risk assessment process to begin with.
Yet BfR and subsequently Codex Alimentarius continue to use this data to create a maximum permitted level for nutrients. Vitamins A and D, Beta-Carotene, Niacin (as Nicotinic acid), Sodium, Potassium, Calcium, Iron, Iodine, Zinc, Copper, and Manganese are all added into the High risk category, while the best that any other nutrient or mineral can hope for is the Low risk category. None fall into a no-risk category, because no such category exists in this type of study.
Clearly, as one can see from the BfR results, the levels suggested by Codex for the Maximum Permitted Levels are excessively low. For instance, the most liberal dosage allowed is for Vitamin C at the levels of 225 mg. Yet the Upper Safe Levels of Vitamin C are nowhere near this small amount.
Even according to Medline Plus, administered by the National Institute of Health and the U.S. National Library of Medicine, the Upper Safe Levels for Vitamin C is 2,000 mg for adults above the age of 18. This is a difference of 1,750 mg set by an agency that is not considered exactly friendly towards nutritional supplements or natural healthcare. Of course, for individuals with some kind of sickness such as cancer, the limits on Vitamin C intake are much higher.
The limits placed on Vitamin D are perhaps the most egregious. BfR sets the Maximum Permitted Levels of Vitamin D at 5 mcg while even the Medline service lists the Upper Safe Limits at approximately 50 mcg (2000 IU). A comparison of the Upper Safe Limits set by the Medline Plus system (under the direction of the aforementioned government agencies) can be viewed by going on to the Medline website and the BfR site.
Keep in mind, as mentioned earlier, that the U.S. agencies who established these Upper Safe Limits are not exactly those that can be considered champions of health freedom, natural healthcare, or nutritional supplementation. Using their figures, however, provide an opportunity to see just how dramatic a decrease in the level of nutrition is caused by BfR’s Maximum Permitted Levels.
While some of these differences are smaller in scale than others, most BfR MPLs are much more than double their Medline counterparts. The standards for copper are quite telling as there is a 10,000 mcg difference between the two.
The problem, however, goes even deeper than the establishment of MPLs and USLs. The Recommended Daily Allowances (RDAs) are of great concern as well. This is not only because they are often instrumental in the setting and justification of MPLs and USLs, but also because they are referenced for human health and individual intake.
In the United States, the RDA is often taken in conjunction with the Estimated Average Requirement (EAR) under the umbrella of the Dietary Reference Intake (DRI) which is set by the Institute of Medicine of the National Academy of Sciences. The RDA is officially defined as “the average dietary intake level that is sufficient to meet the nutrient requirement of nearly all (97 to 98 percent) healthy individuals.” The EAR is defined as “the daily intake value that is estimated to meet the requirement . . . in half of the healthy individuals in a . . . group.” It goes on to say, “At this level of intake, the other half of a specified group would not have its nutritional needs met.”
While this article will not deal in depth with this subject, it should be noted that the Institute of Medicine of the National Academy of Sciences has recommended that the national standard of nutritional intake be shifted from the RDA to the EAR. This would effectively slash the DRI by close to half due to the fact that the original referenced values of nutritional intake would be affected likewise.
Another main concern related to RDAs is the fact that they are not adequately set to promote optimal human health. Indeed, RDAs are set at the lowest level for prevention of single-nutrient deficiency diseases. This means that the RDA is not the level at which intake of a particular nutrient is sufficient for good health, but the lowest level that must be maintained in order to prevent a particular deficiency disease.
In the case of Vitamin C, for instance, the diseases would be scurvy or rickets. Put plainly, RDAs are the levels of nutritional intake needed to barely get by, not remain healthy. As James South points out in his article, “Vitamin Safety, RDAs and the Assault on Vitamin Freedom,” the Recommended Dietary Allowances from 1980 plainly stated as much. South quotes them as saying:
The requirement for a nutrient is the minimum intake that will maintain normal function and health . . . For certain nutrients, the requirements may be assessed as the amount that will just prevent failure of a specific function or the development of specific deficiency signs – an amount that may differ greatly from that required to maintain maximum (i.e. optimum) body stores.
This is a source of confusion for many consumers who believe that RDAs are the levels at which their intake is topped out and adequately achieved. Add to this the fact that RDAs are continually being lowered by the agencies responsible for setting them.
In 1989, the National Academy of Sciences revised the RDAs from their already meager levels set in 1980 to even lower levels, some of them by half. Interestingly enough, the National Academy of Sciences exercised some twilight-zone logic similar to Codex Alimentarius when these decisions were made. The assumption made by the agency was that Americans are generally healthy people and, because they generally fail to consume the 1980 RDA levels of nutrients, then a lower standard is adequate for good human health.
Clearly, either lowering the RDAs or creating MPLs is a threat to the natural supplement industry from the perspective of the consumer as well as the manufacturer. Even without acknowledging the ideological and financial reasons behind the push to end access to vitamin and mineral supplementation, the setting of MPLs, especially at low levels, would create a vast increase in the cost of supplements wherever they were sold. Consumers would then be forced to purchase many more times the amount of supplements to achieve the same result as their current dosage.
If the MPLs reduce a supplement’s levels by half, as many do, then the consumer would need to take two capsules for every one he/she currently takes to achieve an equal amount of nutrition. Translate this into buying two bottles for every one bottle purchased at the current levels. This would not only have a crippling effect on consumers, but the industry itself would face similar repercussions as the option of natural supplementation would become unaffordable. Even the supplements themselves would suffer, as each capsule/pill/dose would therefore have to be produced using more filler materials than actual nutrients.
This is actually a concern with another Codex policy that is much less well-known than that of MPLs – minimum levels of nutrients. While many may see this as contradictory to Codex’s general position toward natural supplements, it is in fact included within the Codex Guidelines. Section 3.2.1 of the Guidelines states, “The minimum level of each vitamin and/or mineral contained in a vitamin and mineral food supplement per daily portion of consumption as suggested by the manufacturer should be 15% of the recommended daily intake as determined by FAO/WHO.”
No doubt some, out of ignorance, will assume that this position is positive. In fact the opposite is true. The setting of minimum levels is merely part of a two-pronged attack on vitamin and mineral supplements, and levels of nutrition in general. The problem with this position is that it prevents manufacturers from adding trace amounts of vitamins and minerals to supplements that may be desired or needed to aid in the processing of the main nutrient. Instead, filler will have to be added. As Scott Tips writes:
Besides the obvious moral problem of prohibiting people from freely and voluntarily contracting with one another as they wish, the practical problem with minimum levels is that they foreclose manufacturers from adding something useful (such as a vitamin or mineral) in a capsule or tablet instead of something worthless, like a filler or excipient. In my view, it would be better for a person to get some additional nutritive value from a capsule or tablet, than nothing at all.
Keep in mind, the MPLs of vitamin and mineral supplements will be set so low, according to the risk assessment studies like those of BfR being conducted, that it will be virtually impossible to include trace amounts of supplements below the required 15% of the already low levels of the RDA. They might as well not be included at all, which is the goal of Codex in the first place.
 “ Use of Vitamins in Foods: Toxicological and nutritional-physiological aspects.” Domke, A., Grosklaus R., Niemann B., Przyrembel H., Richter K., Schimdt E., WeiBenborn B., Worner B., Ziegenhagen R., Federal Institute for Risk Assessment, BfR, 2005. P.18.
 “Vitamin C.” Medline Plus website. http://www.nlm.nih.gov/medlineplus/druginfo/natural/patient-vitaminc.html Accessed April 15, 2010.
 “Vitamin C.” Oregon State University. Linus Pauling Institute. http://lpi.oregonstate.edu/infocenter/vitamins/vitaminC/ Accessed April 15, 2010.
 “Vitamin D.” Medline Plus Website. http://www.nlm.nih.gov/medlineplus/druginfo/natural/patient-vitamind.html Accessed April 15, 2010.
 South, James. “Vitamin Safety, RDAs and the Assault on Vitamin Freedom.” National Health Federation. March 2004. http://www.thenhf.com/articles_19.htm
“Guidelines for Vitamin and Mineral Food Supplements.” http://www.codexalimentarius.net/web/standard_list.do?lang=en
 Tips, Scott C. “Codex Gets One Step Closer To Control.” Codex Aliementarius: Global Food Imperialism. Ed. Scott C. Tips. P.49-50. 2007.
Brandon Turbeville is an author out of Mullins, South Carolina. He has a Bachelor’s Degree from Francis Marion University where he earned the Pee Dee Electric Scholar’s Award as an undergraduate. He has had numerous articles published dealing with a wide variety of subjects including health, economics, and civil liberties. He also the author of Codex Alimentarius – The End of Health Freedom