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To: IAHF LIST
Subject: EMERGENCY! Codex Comments Due Friday: Must Be Sent to FDA re Codex Vitamin Issue Here are My Comments. More Groups and Individuals must file comments with FDA in order to neutralize CRN's/ and "CHPA" pro pharmaceutical comments. Use mine as boilerplate. Just echo them and put your name on them if you don't have time to generate your own!!
From: John Hammell jham@iahf.com
Date: Thu, 04 May 2000 01:16:42 -0400

All Webmasters: Please post.

Everyone Please forward widely and file your own comments with FDA by email,deadline this Friday 5/5/2000 Use mine as boilerplate and add your endorsement if you don't have time to file your own.

Donations needed to get to Germany for Codex meeting: IAHF POB 625 Floyd
VA 24091 USA.

IAHF LIST:

Despite my car breaking down en route, I made it to DC for the first of two pre Berlin FDA Codex Vitamin meeting on monday, and as usual, they're trying to throw us a serious curve. Waiting for me at the FDA's office building at 200 C St. SW were a half dozen burly Washington Capital Police officers who the FDA had called in expressly to harrass me. They confiscated my camcorder and small tape recorder after giving me the fine tooth comb search routine. After the meeting they wouldn't let my friends and I eat lunch in the FDA cafeteria, but forced us out out of the building at which point all the police filed out and went over to their cars.

I walked over to them and complained about being on the Watch List demanding that they stop following me, compiling dossiers on me and violating my 4th amendment rights to protection against unreasonable search and seizure. I also called Special Agent Horan at the Washington Capital Police insisting that they and the FBI stop violating my rights, and that they obey their oaths by arresting the killers at FDA!

I need for more groups and individuals to join me in filing comments to the FDA by Friday and cc them to me. They should be sent c/o Ellen.Anderson@cfsan.fda.gov (See mine below.) Feel free to write your own, or use mine as boilerplate if you agree with them or any combination- but DO get them in because a VERY ORGANIZED pharmaceutical campaign to TAKE OVER the supplement industry is WELL UNDERWAY, and without more of a team effort- we're done for! See http://www.fao.org/waicent/faoinfo/economic/esn/CODEX/cnfsdu22/Nf00_01e.htm for the agenda of the upcoming Codex meeting in Berlin to which I am commenting below.

All it would take for the FDA to get DSHEA repealed would be for the democrats to get just 6 more seats in the House. If the democrats can retake the House, that would put Dingell and Waxman back in power, and Dingell vowed in USA Today to repeal DSHEA. Such an effort we can expect to see as part of CODEX harmonization.

After downloading all of the material pertaining to the Agenda for the upcoming Codex meeting in Berlin into a loose leaf notebook on Sunday, I finally left Floyd by 8:30 pm. I was tired and was trying to make it to Charlottesville, 3 hours from DC by 11 pm in order to get a decent nights sleep then continue on to DC in the morning for the meeting when my timing belt broke and the Plutomobile coasted over to the side of the highway- dead as a doornail. Luckily there was no damage to the valves so I didn't have to rebuild the head, but I did have a nearly $600. repair. While the car was in the shop I made it the rest of the way to DC by Greyhound bus, and changed into my suit in the bus bathroom. I mention this in order to illustrate my determination to sink these bastards. I would have HITCH HIKED to DC had that been my only option because I clearly see how the other side is proceeding with their takeover campaign.

HERE ARE THE COMMENTS I SENT TO FDA

Sent to: Ellen.Anderson@cfsan.fda.gov

Introduction (Specific Comments to Agenda Items and Sub Sections Follow)

International Advocates for Health Freedom, the world's largest group of antiregulatory vitamin and herb consumers demands that the FDA do more than just pay LIP SERVICE towards upholding current US law at the upcoming Codex meeting of the CCNFSDU in Berlin.

Specific comments following these general comments follow, along with the presentation of two attached files: Dr.Rick Malter's REBUTTAL to the National Academy of Science's paper "A Risk Assessment Model for Establishing Upper Levels for Nutrients" along with Darlene Sherrell's expose of the fraudulent fluoride data that was included in the NAS paper which the FDA is clearly now trying to spread internationally to threaten millions world wide with skeletal fluorosis and other serious illnesses. It isn't enough for FDA to commit heinous acts of genocide in the USA, they now seem hell bent on exporting their murderous policies to the rest of the world, while simultaneously attempting to stab the American dietary supplement consumer in the back through an obvious attempt to make an end run around current US dietary supplement laws.

In past meetings, the FDA has merely GONE THROUGH THE MOTIONS of upholding US law by stating that "we oppose ongoing development of the Codex vitamin standard" while simultaneously doing everything humanly possible to ignore US law and to assist the pharmaceutical industry in generating consensus geared towards ultimate passage of a very restrictive standard at step 8.

This is again made clear via Agenda Item #10 of the current upcoming CCNFSDU meeting through the discussion paper which the FDA developed in conjunction with the FDA's of Germany, Denmark and France wherein the FDA includes their "Guidance for Industry: Significant Scientific Agreement in the Review of Health Claims for Conventional Foods and Dietary Supplements".

IAHF reminds the FDA that they are currently being held in contempt of court for violating a Judge's order in the Pearson v Schalala case, that there is no scientific way the FDA can EVER define what they mean by "significant" given that any attempt to so define that word would merely be their opinion which is subject to debate, and the American people do not feel that it is at all appropriate under the circumstances for the Agency to attempt to impose these arbitrary and capricious so called " significant scientific agreement standards" on the people of the WORLD via CODEX!!!

IAHF reminds the FDA that they have been told in writing by Congressmen Burton, Paul, Cook, Stump, and De Fazio NOT to put the heavily biased, grossly unscientific National Academy of Sciences paper "A Risk Assessment Model for Establishing Upper Levels for Nutrients" on the table at Codex per the wishes of John Hathcock and CRN.

We remind FDA that we are painfully aware that a "good ol' boy" syndrome obviously exists between former FDA employee Hathcock and Beth Yetley with regards to the NAS paper, and that neither it, nor any of the other "Discussion Papers" which the FDA has either commissioned, or participated in drafting ever underwent ANY public comments period in the USA for the sake of getting feedback. This violates the Administrative Procedures Act. We remind the FDA and Congress that the National Academy of Science is NOT part of the government, so is therefor not subject to the Freedom of Information Act despite the fact that Federal Funds were in part used to generate the so called "risk assessment" paper. (Which was also generated via pharmaceutical donations in a very clear conflict of interest- especially given that Hoffman La Roche was one of the funders, when they were found guilty of price fixing in the sale of vitamin raw materials by the Department of Justice in 1999 and were fined $500,000,000. It is clear that what the pharmaceutical companies could not achieve via their price fixing scam, they're trying to achieve via CODEX, via the Dispute Settlement Body of the WTO which will no doubt regard the NAS paper to be the "gold standard" on vitamin safety.

This sets the USA up to be forced in a trade dispute to harmonize to a Codex standard which the FDA is clearly doing nothing to try to kill.

IAHF demands that FDA IMMEDIATELY uphold current US law as clearly expressed under the Proxmire Vitamin Act of 1976 which protects consumer access to high potency vitamins and as expressed under the Dietary Supplement Health and Education Act of 1994 by REMOVING the NAS paper, and ALL OTHER discussion papers which FDA has participated in drafting from the table at CODEX and must REPLACE these papers with a paper which tells the TRUTH about vitamin safety- a move that would be consistent with the will of the American people and the will of Congress. IAHF reminds the FDA that it is ILLEGAL for them to take ANY ACTION fostering completion of the CODEX vitamin standard, including efforts through ANY discussion paper to "build consensus" on the issue, given that doing so contradicts the amendment to the FDA Modernization Act of 1997 which expressly EXEMPTED dietary supplements from the harmonization language of that bill (which effected everything ELSE that the FDA regulates under the Food Drug and Cosmetic Act.)

IAHF totally rejects the obvious LIES of FDA attorney Melinda Plaiser who has argued that we are "misinterpreting" the GATT agreement. As evidence that the WTO's Dispute Settlement Body has in FACT been forcing the US to harmonize its laws to international standards, we invite the FDA to peruse the "Harmonization Alert" section of Ralph Nader's "Global Trade Watch" website at http://www.tradewatch.org

IAHF reminds the FDA that due to their actions the sort of protests seen in Seattle and DC will only continue in Berlin unless they start obeying current US law, and STOP catering to the multinational companies which dominate both CRN and NNFA. These pharmaceutically manipulated vitamin trade associations DO NOT reflect the will of the American people, or the will of consumers of dietary supplements ANYWHERE in the world!

IAHF calls upon consumers world wide to assist Dr.Matthias Rath (http://www.rath.nl) in demonstrating AGAINST the genocidal Codex meeting of the CCNFSDU in Berlin between June 19-23, and encourages Dr.Rath's efforts to flood Codex delegates world wide with protests by utilizing the menu on his website set up for the purpose of sending his form letter of protest. IAHF demands that FDA uphold US law by VIGOROUSLY and EMPHATICALLY calling for an END to ALL DISCUSSION on the Codex vitamin issue. Consumers have been angrily demanding this since Geneva in '97 and we're STILL demanding it, and we DON'T LIKE the constant efforts being made to deceive us via such PSEUDO SCIENCE as the NAS so called "risk assessment" paper.

SPECIFIC IAHF COMMENTS ON THE AGENDA FOR CCNFSDU in BERLIN, June 19-23 2000:

Agenda Item #1: Adoption of the Agenda: IAHF opposes the entire agenda and feels that the meeting should not take place. IAHF endorses the actions of Dr.Rath and the demonstrators in the street who totally oppose the meeting. IAHF demands that the FDA oppose the entire agenda as the entire Codex process goes against our whole system of representative government. If the Codex vitamin proposal should ever be shoved down the throats of the American people, IAHF hereby puts the FDA on notice that in THIS country power flows from the PEOPLE to the GOVERNMENT, and NOT the other way around and if our rights are ever trampled, and our laws are ever harmonized to a restrictive Codex standard blood will flow in the street!IAHF reminds the FDA that we reserve our 2nd amendment right to bear arms in the face of this madness should our numerous peaceful entreaties go unheeded.

IAHF informs the government that John Hammell has entered into a legal contract with his jurisdic person via the Uniform Commercial Code to remove himself from the criminal dictates of Admiralty law, and encourages all Americans to follow suit so as to retain the Constitutional Rights which have otherwise been usurped by our criminal government and their globalist corporate masters who have monetized our birth certificates as collateral against the national debt and who clearly seek to enslave us. IAHF informs the FDA, Washington Capital Police and FBI that numerous Supreme Court first amendment decisions in the 1950's uphold my first amendment right to express the opinion that government officials who ignore their constitutional oaths should be killed as enemies of the people. It is NOT an illegal threat to make this statement, it is protected speech under the first amendment.

It IS illegal for the FBI and Washington Capital Police to follow me around, compile dossiers on me, and otherwise violate my 4th amendment rights to protection against unreasonable searches and seizure. It is illegal for the FDA to block me from videotaping, photographing or tape recording any of their meetings as I am a member of the press, regardless of whether or not I have been issued a so called "press pass."

Agenda Item #2:

1.1.1 Amendment to the Rules of Procedure:

IAHF rejects rule X2 which stresses the need for "consensus" as the whole Codex process goes completely against every basic tenet of American Representative Government and the USA shouldn't even be participating in this so called "process" at all. Unelected bureaucrats from the FDA do NOT represent the will of the American people, thus the whole Codex process is obviously a shell game put on to give the APPEARANCE of fairness in an effort to DECEIVE consumers world wide. The USA must REFUSE TO PARTICIPATE in this undemocratic process unless provisions are made for the USA to be represented by ELECTED OFFICIALS WHO CAN BE VOTED OUT OF OFFICE (NOT unelected bureaucrats) and unless the voting process be expanded to include NGO organizations, and unless it be changed so that a country can have voting power proportionate to its population.

Moreover, IAHF, which was unjustly refused NGO status by the UN due to our opposition to the UN, hereby RETALIATES against the UN by endorsing congressional cosponsorship of Ron Paul's American Sovereignty Restoration Act which would REMOVE US from the UN/WTO ENTIRELY!!! It is obvious to IAHF that the UN will only grant NGO status to entities that do not oppose the UN! This is DICTATORIAL and UNAMERICAN and IAHF consumers world wide oppose such GROTESQUE TYRANNY!

1.2 Principles of Risk Analysis: IAHF rejects the Commission's recommendations pertaining to "Risk Assessment" especially in light of the numerous scientific flaws existent in the NAS paper which is thoroughly rebutted by Darlene Sherrell's expose on the fluoride data, and especially via Dr.Malter's rebuttal (included herein) which lays bare its numerous flaws. IAHF wonders what the Commission has in mind when it talks about "exposure studies" in "i". Our guess is that it favors such unscientific data collection efforts as the FDA's so called "Medwatch Program" wherein FDA collects unconfirmed annonymous case reports in an effort to falsely depict safe vitamins as "dangerous". The GAO has examined this with regards to ephedra, and has voiced strong disgust with FDA's gross lack of scientific accuracy in how they're collecting alleged adverse reaction data.

In light of the above concerns, IAHF totally rejects the Medium Term Plan 1998-2002 pertaining to Nutrition and consumer information and commodity standards. As long as the Commission is planning on utilizing unscientific "risk assessment" methodology such as that proposed by the NAS, nothing about this long term plan can be trusted as it clearly goes against the public health.

2.1 #55: IAHF agrees that nutrition labelling is a topic that should ONLY be addressed by national authorities, taking into account each countries specific public health needs.

#62: IAHF totally disagrees with the position of Norway and so called "Consumers International" which is that "health claims should not be permitted as they were misleading to consumers and that only a balanced diet would provide health benefits." IAHF questions the motives of "Consumers International" which seems to us to be shills for the Drug Cartel. Perhaps this is why they were granted NGO status while IAHF was not.

3.2 IAHF rejects the joint FAO/WHO Expert consultation on human vitamin and mineral requirements, Bangkok Thailand, 21-30 September 1998 as IAHF could not afford the cost required to travel to Thailand and was excluded in any case from participation. IAHF rejects all acronyms used in the report due to the exposes of Dr.Brian Leibovitz who has published articles relative to their scientific fraudulence. Such acronyms include "RNI, EAR, UL" and others. IAHF rejects all findings pertaining to bioavailablility of nutrients due to the obvious conflict of interest wherein mainstream nutritionists developing such figures are all being paid via pharmaceutical research grants. Dr.Leibovitz, former Editor of the Journal of Applied Nutrition, and of the Journal of Optimal Nutrition has commented extensively on the scientific falsity of the methodology employed in studies such as this via such articles as "The ABCs of Confusion as a Weapon" which can be downloaded off the IAHF website http://www.iahf.com IAHF TOTALLY REJECTS all the RNI data included in the table in the report due to the fact that it does not take into account widely varying differences in individual needs- it ignores the whole issue of biochemical individuality and must therefor be scrapped as valueless. IAHF would like to see the CVs of all participants listed in the report for the sake of examining how much money they receive via pharmaceutical research grants.

AGENDA ITEM #3 "Guidelines for the Use of Nutrition Claims: Draft Table of Conditions for Nutrient Contents"

IAHF scoffs at the Australian concept of including white bread as a listed "SOURCE OF FIBER" claim and concludes that the Codex process is obviously dominated by know nothing morons from groups such as the American Dietetic Association and its international counterparts who manage to kill scores of people in hospitals world wide who are subjected to malnutrition via diets which include white bread, jello, and that atrocious rubbery "minute" steak which takes at least 3 days to digest.

AGENDA ITEM #5: Proposed Draft Guidelines for Vitamin and Mineral Supplements:

IAHF demands that FDA not only uphold current US law by demanding that all deliberations on this agenda item immediately and permanently CEASE, but IAHF also demands that FDA do more than pay LIP SERVICE in this regard.... We demand that FDA immediately UPHOLD current US law by REMOVING the unscientific NAS so called "Risk Assessment" paper from the table in light of Dr.Malter's paper (attached) and Darlene Sherrell's expose on the fraudulent fluoride data (attached.) We demand that FDA put a paper on the Codex table that is consistent with the will of the American people as clearly expressed under Proxmire and DSHEA. This paper should discuss the views of Dr.Roger Williams, discoverer of Pantothenic Acid who developed the concept of optimal nutrition and biochemical individuality.

Further, IAHF demands that FDA rescind all comments made in ALL discussion papers pertaining directly or indirectly to the Codex vitamin issue because by participating they are making an effort to build consensus towards eventual completion of a standard, which is illegal under US law for FDA to even attempt to work towards in any way shape or form! This has been clearly stated in writing by Congressmen Burton, Paul, Cook, Stump, and De Fazio the gif file of who's letter to FDA can be seen at http://www.iahf.com Digitized footage of Dr.Yetley of FDA ignoring this letter can be viewed at http://www.lef.org

IAHF opposes the concepts of positive AND negative lists, because either method burns consumers and runs diametrically against the public health.

Preamble: IAHF demands that the preamble be scrapped entirely. It reads "Most people who have access to a balanced diet should usually obtain all the nutrients they require from their normal diet. People should therefor be encouraged to select such a balanced diet from food before considering any dietary supplement."

This "Preamble" exposes the whole pharmaceutical agenda to stop people from using vitamins to improve their health. The statement does not take into account individual nutritional needs, the depletion of nutrients from the soil, the stresses put on people today due to pollution or anything else. It is a mindless assertion, and is typical of the whole mindset of the pharmaceutical interests who are conspiring to destroy the dietary supplement industry.

2.1 Remove square brackets.

3.1.1 Scrap whole section, especially the garbage in square brackets pertaining to risk assessment.

3.1.3 Scrap entire section- IAHF does not trust CODEX to make any determinations whatsoever about safety!

3.1.4 Scrap whole section as it hinges on section 3.1.1 which also must be scrapped, especially the mindless drivel in square brackets about "proving efficacy."

3.2.2 Scrap the whole section. It goes totally against the public health to try to limit maximum potencies to 100% of the RDA given that the RDA is fraudulent. The comment about wanting to limit potency below the range that produces pharmacological effects is mindless and clearly indicates the pharmaceutical agenda.

3.2.1 Scrap the whole section. Totally reject notion that NAS risk assessment methodology is in any way valid.

3.2.3 Scrap whole section. The RDI is a scientifically fraudulent concept. This is another arbitrary attempt to screw consumers by blocking access to vitamins and minerals within the therapeutic range.

4. Food Additives JECFA has not taken into account a lot of different fillers used in vitamin products. Scrap the whole section.

7.3- It is unreasonable to expect vitamins to be sold in child proof containers. Vitamins aren't dangerous and aren't drugs.

Agenda Item #9: Discussion Paper on Review of Provisions for Vitamin and Minerals in Codex standards: Vitamins and Minerals in foods for Special Medical Purposes.

IAHF rejects the concept of the "UL" as discussed in this paper.

Agenda Item #10: Discussion paper on the Scientific Criteria for Health Related Claims: (Prepared by USA, Germany, Denmark, France.)

It was illegal for USA to participate in drafting this paper. Doing so fosters the building of consensus on the Codex vitamin issue when to encourage their development violates current US law. It is especially offensive that FDA has included its "Guidance for Industry- Significant Scientific Agreement in the Review of Health Claims for Conventional Foods and Dietary Supplements" given that there is no scientific way the FDA can define what is meant by "significant" given that any "definition" would just be FDA's opinion. Given that FDA is currently in contempt of court for ignoring the Judges order in Pearson v. Schalala, it is obvious that FDA is trying to go through Codex to impose their will in this regard not only on Americans, but also on people world wide. The so called "Significant Scientific Agreement" standard is a tautology. It means whatever FDA wants it to mean and can't be scientifically defined. As such it is arbitrary and capricious.

Agenda Item #13: "Recommendations of the FAO/WHO expert consultation on food consumption and exposure assessment of chemicals: Discussion paper for the incorporation of nutrient intake assessment in a risk based approach to assist decision making process of CCNFSDU

IAHF rejects this discussion paper due to the credence it lends to the NAS risk assessment paper.

The NAS Risk Assessment Model for Establishing Upper Intake Levels for Nutrients:

A Critical Review From a Psycho-physiological Perspective


Fraud or Incompetence?

NAS/NRC Institute of Medicine Dietary Reference Intakes