To: IAHF List
From: "International Advocates for Health Freedom"
Date: Fri, 13 Apr 2001 18:06:37 -0400
Subject: Let the Leibovitz Debate Continue: - As Race to Bottom Begins:

IAHF List: Here ends the debate over "Safe Upper Limits" that Cartel friendly, junk science contrived control mechanism, currently under artful deployment by the sold out echelon of the dietary supplement industry. Is "playing the game" the best way to defend our access, or is civil disobediance combined with TRUE science the REAL answer?

See the NEW, much IMPROVED anti Codex Video at showing speeches from the demonstration, aerial photos of the demonstration and roof of the Bgvv building where the Codex mtg was held last June, see speeches from Dr.Rath's Counter Meeting, and send the form letter which has space for your personal comments to every single member of the European Parliament and European Commission. See video footage that takes you inside the human body and explains in simple terms Rath's and Pauling's Solution to the Problem of Human Cardiovascular Disease.... we don't need sold out pro Cartel "junk science" to "defend" our access to vitamins, (don't buy into that con), we need REAL science combined with civil disobediance, and Rath delivers both. When you have a driving force..... go with it.

[Webmaster's Note: To easily follow this discussion, Ron Law's comments are in italics; John Hammell's comments are in regular text]

At 10:45 AM 4/12/01 +1200, Ron Law, proponent of "Upper Limits" for vitamins wrote:

If you have read my OHT's you would know that I too firmly support the optimal nutritional intake concept - I'd reached that conclusion by myself without having read Leibovitz at that time.

Your overhead projector transparencies from the Pharma Cartel's IADSA meeting will take 2 weeks to arrive from S.Africa. Thats the fastest PHARMAPACT can get them here and they just sent them out because Stuart and Ant were busy on projects, but I don't need your Over Head Projector Transparancies to make transparent the U.L. scam, or to make transparent the "race to the bottom".

At there are several new videos that REALLY make the Codex Vitamin issue transparent by taking you inside the human body to visually show everyone Rath and Pauling's discovery vis the nutritional ANSWER to human cardiovascular disease, which the CARTEL is so desperate to suppress through Codex via junk science derived, "Safe Upper Limits" which utterly fail to take into account biochemical individuality, and threaten to lock us into a regulatory straightjacket.

Also on this new Rath site is a NEW, much BETTER video of our anti Codex Demonstration last June which even includes AERIAL photographs of our demonstration, shows the roof of the Bgvv Building where the Cartel is conspiring to suppress our access, footage from speechs at the demonstration, and footage from our COUNTER CODEX MEETING where Herr Grossklauss is quoted stating flat out LIES, which Rath refutes by citing the medical literature.

There is also a new form letter from Rath, with a space for people's personal comments, to every member of the European Parliament and the European Commission, inviting them to his site to see the visual evidence themselves, to literally see inside the human body in order to understand his and Paulings pioneering nutritional discoveries.....

BACK to this discussion of the unecessary Cartel Friendly Control Mechanism: The wholly unecessary "Safe Upper Level" or "UL":

You say, "he didn't advocate that people go around ingesting arsenic, cadmium, lead, silver, he would support limits on iron, he would not support ingestion of mercury, he did endorse limits on D, and A. He wasn't opposed to the idea of scientific risk assessment, he just didn't consider Hathcock's concepts to be legitimate, "

John Hathcock's RA is flawed in that he doesn't make provision for the risks associated with low intake. This was discussed at the IADSA meeting - I spoke immediately before John and I raised that point in my paper and he acknowledged that in his presentation. I used several examples. Selenium -the risk of too little? Cancer. The risk of too much? Brittle fingernails and hair and garlic breath with (mostly reversible) neuropathies in extreme cases. What do the regulators worry about? Garlic breath and the state of wellbeing of their hair and fingernails. I argue that they should be moving away from the highest risk and towards the lowest. My personal view? Optimal intake for selenium is in the 300-400 ug intake from all sources.

Leibovitz would not agree. The fact is that a person with an acute infection eg: AIDS could safely absorb 3 times as much selinium (1200ug or more) necessary to manufacture sufficient oxidative enzymes to meet his immune systems needs, and this arbitrary UL would make it far more difficult for him to obtain the amount of selenium he would need affordably.

Thats the Cartels' goal in wanting to set these "UL"s- to stop people from having easy access to the amounts necessary to bring about healing. They are trying to put arbitrary caps on available potencies of these substances. The only way you could really know for sure if a UL is meaningful would be to do clinical trials on different patient populations, and that would obviously be the NEXT regulatory barrier they would try to set, especially since individual nutrients aren't patentable (unless molecularly tweaked), so not even most pharmaceutical firms would bother- but this would really pull the nutrient thorn out of their side and block this shift towards prevention which is raising increasing hell with the sales of their patented drugs.

This would be their next move if they could first get their foot in the door with "UL"s and set us all down this very slippery slope to start with. Some companies would get around the problem of individual nutrients not being patentable by molecularly tweaking them, as Sigma Tau did with the amino acid L-Carnitine, to make a drug version of it that they call "Carnitour."

I still have the transcripts from a public meeting that FDA held in about 1991 after passage of the Nutrition Labeling and Education Act to solicit public input prior to their rulemaking on this bill. Sigma Tau actually openly requested that FDA help them out by banning natural L-Carnitine, as they wanted their DRUG version to be the ONLY L-carnitine allowed to be sold in the USA. Stephen De Felice, MD, who holds the patent on "Carnitour" coined the term "Nutraceutical" a term which I despise and will never speak aloud as long as I may live. This obscene individual embodies the greed of the Pharma Cartel, which has become indistinguishable from the greed of the sold out sector of our industry - and it is that sold out sector that is playing this "risk assessment" game.

They really don't care what they sell, as long as they can have a monopoly, so maybe they'd keep selling nutrient products, but only if they could shift everything to full HACCP standards and devise a scheme for exclusivity rights in order to first knock all the small companies completely out of business. We're already seeing this roll up process occurring now, especially through the press release of the Trans Atlantic Business Dialogue's Dietary Supplement Working Group at

Leibovitz would say there should be basic suggested amounts of selenium for a range of people (to have at least some flexability in the recommendation) and a simple warning about excessive consumption. PERIOD- What you are suggesting is a regulatory straightjacket with no flexability, doesn't take into account the form of the substance, doesn't take into account the condition of the person who will be taking it, eg: hydrochloric acid availability in the stomach. The GOAL of this UL Scam is simple: to pick our pockets and to set us down a slippery slope to oblivion- to controlled clinical trials.

It is an artful maneuver, much like the adroit moves embodied in a sleazebag pickpocket team working over the crowd in Grand Central Station. Theres the distractive bump and stall, simultaneous to the pick, practiced, and honed like a hoodlums switchblade knife- ready-for the coup de grace: controlled clinical trials- the barrier through which a multifactorial vitamin treatment protocol may not pass as long as the Gatekeepers are companies like Hoffman La Roche, whose goal is NOT health freedom, its to create a MONOPOLY on natural health products.

Over 100 different people from all over the world on the IAHF list emailed Peter Heer of Hoffman La Roche because he is listed on the TABD press release "U.S. and European Leaders Agree on Principles to Harmonize Dietary Supplement Regulations" to ask questions pertaining to this non transparent TABD "process" (which is intent on scuttling domestic US vitamin laws, grossly ignoring the thoroughly expressed will of the American people.) TO NO AVAIL. Mr.Heer refuses to discuss Hoffman La Roche's non transparent plans for us, and it is clear that TABD/IADSA don't care one whit what consumers want.

Folic acid: The risks of too little intake? Cancers, heart disease, anaemia, Neural tube defects, Alzheimer's, etc. The risk of too much intake? A hypothetical unproven masking of neuropathies due to B12 deficiency which could easily be prevented (if it actually happens and having thoroughly analysed the 1940/50's papers that the NAS supposedly used in their RA there is no evidence that it does happen) by adding B12 with folic acid - a stunningly simple risk management option. Fenech has shown quite conclusively that about 700 ug of folic acid is required to maintain normal genome function, but this is never considered in any risk analysis I've seen. Optimal Nutrition intake for folic acid, in my humble opinion, is about 1,000 ug from all sources.

See above, same problems with ANY so called "UL" Allegedly this is "scientific" risk assessment? How is your 1,000 ug from all sources "scientific" ? To really know how much folic acid any given individual is getting from food sources, you'd need lab work. Thats what the cartel would say too. The moment we start down this UL route its a slippery slope to the bottom, putting the Cartel in control, giving them every opportunity to keep raising the bar. In every country where this UL route is being advocated, the companies pushing for it are already registered as pharmaceutical companies.

IADSA is openly run by the Pharma Cartel

Take South Africa as a perfect example: Bruce Dennision, owns VitalPharm- registered in SA as a pharmaceutical company; Elzabe Stoffberg, Natura Labs, registered in SA as a pharmaceutical company; Peter Kraft, Bioforce, registered in SA as a pharmaceutical company; Pharma Natura, Rene Doms, attorney, creator of the S.African listings system in conjunction with his old buddy Peter Folb, former Chair of MCC who he used to work with as head of the MCC Inspectorate. Pharma Natura is ALSO registered in S.Africa as a pharmaceutical company.

At a meeting (that was never publicly announced) when it was first announced by HPASA that a "listings system" was to be established in S.Africa replacing Act 101, (which most role players, not even most HPASA members were unable to attend, but which these big companies sent people to because they could afford the expense involved) Doms passed out a statement that was leaked into Stuart Thomson's hands that said "All 90 members of the HPA were prepared to become full pharmaceutical companies" Note: This wasn't true!

Most could not afford to, but they weren't at this meeting, which wasn't publicly announced, to see what he handed out, so they couldn't object, and Doms realized in advance who would be in attendance and who would not! This was, and still is, an effort by VitalPharm, Natura Labs, Bioforce, Pharma Natura, and Sportron to form a MONOPOLY in S.Africa- and exactly the same thing is happening world wide amongst the natural products industry-Its happening here in the USA - same in Canada - same in Europe - as a handful of powerful supplement companies attempt to knock the smaller players off the cliff while they in turn try to sell out to still larger companies.

This "UL" is "scientific"? Sorry. Its just a politically contrived control freak maneuver to limit available potency levels to consumers, and to set the industry up, for the next oily move- the move to full pharmaceutical GMPs and to required controlled clinical trials, with the gatekeepers being regulatory bodies that are controlled by the Pharma Cartel. This is not "science" this is JUNK science. Malter and Leibovitz called it quite accurately.

You're just trying to do a sales job. Thats what you were hired for, to make dog waste sound like Grade A Sirloin Steak. Your job is to try to make this shit seems palatable, but its NOT - its a SLIPPERY SLOPE very slickly designed to try to seem innocuous. A truly gifted salesman, which I'll grant you, you are, can sell an ashtray, to a non smoker, and at the time, make this SEEM like the absolute BEST. most desirable deal in the history of the universe.

All of this is overkill and anti consumer. Water kills if you drink too much. It can burst your stomach wall. Why aren't they creating a UL on water? It doesn't compete with any pharmaceutical drugs, so they don't care if its possible to drink enough that you could burst your stomach wall, a UL on water would be totally unenforcable, and if anyone tried to establish one, it would expose this farce for what it REALLY is - a pharmaceutically orchestrated control mechanism.

This isn't about safety, this is about control. This is about stealing our vitamins on a basis of junk science. Malter and Leibovitz were absolutely correct. Sure, their arguments can be attacked on a basis of semantics and by splitting hairs, but on the whole, they're absolutely correct. This is why the size of the demonstrations in front of the Berlin meeting is only going to KEEP increasing. We don't want or need a nanny state to tell us what we can, or cannot ingest into our own bodies.

B12: The risks of too little? Pernicious anaemia, heart disease, Alzheimer's, etc. The risks of too much? As John Hathcock says, "I doubt anyone could afford the experiment to find out." The fact is that any risks of too much (if any) are way higher than anyone could actually afford to take. Optimal Nutritional Intake. Probably more than 50 ug in conjunction with folic acid, B6, Mg, Zn, etc. If high risk of vascular disease probably about 500 ug.

Again, you're guessing. This is not "scientific" risk assessment. What if no risk of vascular disease? What if the person wanting to take it is using Rath's protocol to prevent vascular disease? What if the person wanting to take it is taking an optimal amount of C and has really clean unobstructed arteries from taking C and lysine?

What right have you got to set ANY limit on such a person? You don't have that right, neither does anyone. These substances were gifts directly to us from our Creator. They were put here for our use so that we could flip the bird to the pharmaceutical industry whose products constitute the 4th leading cause of death in the world today.

It should be legal, if I wanted to, to take the biggest syringe in existence and to mainline B-12 directly into my arm if I feel like it. It should be legal for me to hook up an IV drip and drip the stuff into my body all night long while I sleep, if I feel like it.

This disgusting waste of regulatory revenue to create "UL"s for already safe substances is UTTERLY outrageous in the face of how these regulatory bastards should be devoting their energies: towards cleaning up our contaminated blood supply, our food supply, and to keep dangerous drugs which they fraudulently approve due to payola, off the market.

If Leibovitz agreed with scientific risk analysis, how would he have done it? Apart from the flaws I've pointed out, I don't see too much wrong with John Hathcock's model. The major problem with it is defining adverse effects and this is where John Hathcock states that the NAS stuffed up (my words) with niacin. As John said at the IADSA conference, they have wrongly confused a nuisance with a harmful event.

True, they did, but where is the "science" in determining ANY of these "UL"s? They're ALL arbitrary. None of them take into account any aspect of biochemical individuality. They can't. Theres just no way to guess at the physical condition of ANY person wanting to use any given product. No way to know about hydrochloric acid availability in the stomach. Doesn't take into account different forms of a substance. All setting "UL"s does is to set the stage for companies like VitalPharm, Natura Labs, Bioforce, and Sportron to KEEP raising the bar once you start down this slippery slope.

Sure, in the end, these companies won't be able to keep up - but they won't care - they're playing the game, positioning themselves to sell out to even LARGER predators higher up the "food chain", the multinational giants circling around employing this Hegelian Dialectic through such change agents as Hathcock (former FDA, and still close buddies with them), and Rene Doms, (former MCC, and still close buddies with them) The people pushing for "UL"s are all one big Circle Jerk of selling out accompanied by that high and mighty feeling of exclusivity that these scum get from flying to the ends of the earth to foist off this odiferously fetid blood sucking scam.

First, the Global Drug Cartel created the problem (threat of regulation). The German multinational giants enter the mix as the "bad cops" while the sold out vitamin companies that are the largest in the supplement industry, registered world wide as pharmaceutical companies and positioning themselves to sell out, enter the mix as the "good cops" and try to con all the smaller companies in their trade associations to "trust us- we'd NEVER steer you wrong! We NEED UL's, its the ANSWER"

Leibovitz saw through this charade, and so do I, its not that hard to see through. All that is needed is basic recommendation for a MINIMUM range of dosages, and simple WARNING labels to warn of POSSIBLE problems with higher doses, but leave it up to the CONSUMER to get lab work if he WANTS TO. This "UL" is designed to cut down available potency levels to KEEP safe substances from being available to use affordably for healing purposes, and its intended to set us down a slippery slope leading to clinical trials, DRUG trials. Any damn fool can see the direction you are trying to steer things in by examining US and EU Leaders Agree on Principles to Regulate Dietary Supplement Regulations......

Ah yes, and the contact person for this press release? Would you believe Peter Heer of Hoffman La Roche, the very same company that was busted by the US Dept of Justice and by the Australian government for engaging in illegal price fixing in the sale of vitamin raw materials for 10 years?

Now- via TABD, IADSA, the EU and CODEX the Cartel has an even BIGGER HEIST in mind. This is why not one single consumer from the IAHF list who emailed Heer for more information re this press release received ANY, and he had no way of knowing they were from the IAHF list because I didn't have a form letter for communicating with him, people did so spontaneously to ask questions which they bcc'ed to me. None were answered...... we are witnessing a crime in progress.

What limits would you put on iron, D, and A? How would he have objectively determined such limits? If you were a regulator responsible for public health, what limits would you set for maximum levels (keeping in mind that people can always take more if they choose, no regulator can stop that.)

Iron - Found in most foods- Childproof caps- Kids have died from ingesting too many iron tablets - as low a dose as 900 mg taken at once has killed. I'd have warning label- NOT limits- kid could just as easily crawl under kitchen sink and drink bottle of Draino as get lucky and open childproof bottle of iron tablets. Symptoms of overdose include headaches, shortness of breath, increasing fatigue, dizziness, weightloss, a gray-bronze skin tone after the iron has been deposited through the tissues. Iron already in most foods, suggested safe intakes: 8-12 mg children,10-15 mg teenagers,10-15 mg teenagers,18 mg women in reproductive years, Pregnant women 30-60 mg pe day Intake hindered by Vitamin E and vice versa,also by tea,coffee,alcohol - key is EDUCATION, not unscientific so called "UL"s.

If a person is out in the sun all day, say a roofer or a commercial fisherman, he'd get a lot of Vitamin D naturally from the sun. You can get a lot from food sources.Researchers have shown that toxicity has occurred in some people at doses of 2,370 IU per day, but what if you have rheumatoid arthritis, psoriasis, or tuberculosis - an adult might take up to about 10,000 IU, and a child up to about 4,000 IU before seeing signs of toxicity. Symptoms of toxicity: anorexia, nausea, vomiting,headaches, excessive urination and thirst, diarrhea and fatige. Calcium and phoshorus levels increase to very high levels. The lungs, kidneys, large blood vessels, heart and other soft tissues become calcified. Anyone with liver or kidney disease or who has problems with intestinal malabsorbtion should check with doctor.

I would not set a UL for vitamin A - too much depends on the individual. I'd use warning label to educate about toxicity symptoms for vitamin A: fatigue, restlessness,nausea, vomiting, head aches, skin rashes, dry scaly lips, hair loss, brittle nails - HUGE doses, approximately 100,000 units taken daily for 3 years- produce toxicity. Only 12 cases of Vitamin A poisoning have ever been reported in the USA according to the USDA. Can you get too much from food, probably not.

I suspect a lot of heat in the risk analysis debate stems from the way the FDA got the NAS risk analysis model put on the Codex table in Berlin in 1998. That's a separate issue. It's not the gun that's unsafe - it the person using it!

I look forward to your response.


Yes, its always a problem when a pharmaceutically dominated regulatory body makes no effort to build consensus on a controversial issue such as this that would impact the largest single body of dietary supplement consumers on Earth, the American people.

That stated, you must exercise caution when comparing dissimilar issues. This is not a gun, its a UL, and you have to examine the people advocating it, and why they're advocating it.

You're recommending UL's which can limit available potencies unreasonably, such as 35 mg for niacin. Just because you and Hathcock now have objections, doesn't mean you will ever be heard and changes made based on your complaint,and I need the stuff, so I oppose ULs across the board, for everything. Neither CRN or IADSA have any vote whatsoever at Codex- a totally undemocratic process that makes a mockery of our system of representative government.

My take on ULs is that they re NOT SCIENTIFIC, the only way they could BE scientific for any given individual, given biochemical individuality, would be through controlled clinical trials- and thats NEXT, but ONLY if we head down this slippery slope to START with, so I say "Don't go there-its not necessary- all thats necessary is warning labels." My take on ULs is that they're being pushed by only the most powerful companies in the vitamin trade associations, the ones already registered as pharmaceutical companies within their countries, and by smaller companies only if they have been conned.

I have given the example of South Africa, all of the speakers from the South African Health Products Assn at IADSA are registered as pharmaceutical companies in S.Africa- Dennison represents VitalPharm, Elzabe Stoffberg represents Natura Labs, Peter Kraft represents Bioforce, Rene Doms, formerly Chief Inspector at MCC (and the attorney who originated the S.African listings system which you endorse) heads Pharma Natura. At a meeting in S.Africa intended to announce the intention to ram through a "Listings System" (called with no public notice, on spur of moment) with the exception of Stuart Thomson, who was tipped off to the meeting, so they didn't expect him there, so he received a secret document in error, nearly all the other attendees were from the aforementioned largest players amongst the HPASA!!

Thomson intercepted a statement from Doms which said that "All 90 members of the Health Products Assn were prepared to register as pharmaceutical companies." This was not true, and NONE of the small companies in his trade association had never been ASKED this! When they found out later they got very angry! This illustrates what is going on world wide. People such as Hathcock and Doms (former FDA, and MCC respectively) are the "engines" pushing this "UL" concept, and they rely on smooth talking salesmen such as yourself to try to "sell" us on this feces sandwhich as if it were sirloin steak. Sorry, I'm not buying it. A really good salesman can sell ANYTHING, but that doesn't mean its not a con. I've seen salesmen who could sell ashtrays to non smokers and make them sound like the most desirable objects in the world. The only REAL question here, is why won't Peter Heer of Hoffman La Roche return anyone's email???

Due to biochemical individuality, the different forms a product can be sold in, the physical state of the individual, there is nothing "scientific" about a "UL" anymore than there is anything "scientific" about a switchblade, or other weapon in the hands of a skilled criminal.

All the "UL" does is set us down the slippery slope towards wholely unecessary controlled clinical trials, and like the switchblade or pair of brass knuckles, it can be used for muggings in what amounts to be a "hold up." Thats the actual purpose of the UL, of course, although the heads of sold out trade associations advocating it will never admit it.

The "UL" is just part of Hathcock's arsenal of weapons of confusion along with the "AER,LOAEL,DRI" and other equally meaningless, intentionally confusing acronyms. Leibovitz and Malter called it correctly. In your zeal to "debate" them all you did was go into a lot of tortured hair splitting via semantics to try to "prove" them wrong. Like I said before, a skilled salesman can sell a good looking ashtray to a non smoker if he's really smooth, and make the victim think, in that moment, that they're getting a "good deal". All the "UL" does is set us down a slippery slope leading to controlled clinical trials, an ongoing raising of the bar. Theres no NEED for it. All we need is warning labels. We don't WANT UL's because they can impact available potencies, forcing consumers to spend an UNREASONABLE amount of money for the safe products they wish to buy- if they can afford them, and if they are still available at ALL by the time TABD screws us by forcing things to full HACCP GMPs.

This debate won't be settled inside the Codex meetings, it will be settled in the streets, between riot police and demonstrators, and a large BLACK MARKET is on the near horizon as the SCREWS keep getting tightened. This is a race...... to the BOTTOM.

See the "Big Brother" Canadian Security Intelligence Service anaylsis of this hijacking of our sovereign rights as the Multinationals ATTEMPT to DICTATE to the world "ANTI-GLOBALIZATION - A SPREADING PHENOMENON

-----Original Message-----
From: John Hammell
Sent: Thursday, 12 April 2001 10:30 a.m.
To: Juderon
Cc: GAIA Research cc; Boris Dragin; Dr B.W. von Ehrenberg; Sarida Brown,Ed; Consumers for Health Choice; Christine Doyle; Colleen Cackowski; Sato Liu; Helen McCormack; David Amrein; Dominic Galvin; Nick; Jonathan Griffith; Tim & Jan Bolen; namaste publishing; Brod Kearon; Martin Forde; Ralph A Pike; Sue Rattigan; Josef Hasslberger; Tamara Theresa Mosegaard; Vitale Onorato;; GS;; Jonathan Griffith
Subject: Re: Let the Leibovitz debate begin

OK John, you've got a debate on Leibovitz article.

Firstly, are there any doses of any vitamin or mineral that you believe should not be able to be sold?

First of all, did you read Leibovitz entire article? You didn't send all of it to me with this email, it continues past the line thats underneath the part where you cut it off in what you sent me (below). His entire article can be seen at under NAS Rebuttal

What are you trying to do? Create another straw man to knock down? How is your question relevant to Leibovitz article? If you want to debate anything he said, debate his specific points. Leibovitz never said all substances are safe, and he didn't advocate that people go around ingesting arsenic, cadmium, lead, silver, he would support limits on iron, he would not support ingestion of mercury, he did endorse limits on D, and A. He wasn't opposed to the idea of scientific risk assessment, he just didn't consider Hathcock's concepts to be legitimate, and his views warrant respect, he was the Editor of the Journal of Applied Nutrition, and also of the Journal of Optimal Nutrition.

For over 20 years he developed almost all of Twinlabs products, working in a strictly volunteer capacity because he was living off a trust fund and did not need their money. He didn't have to publish the Journal of Optimal Nutrition, either, he did so as a public service in order to educate people to the health effects possible through an optimal intake of nutrients. He strongly opposed the RDA and pushed for creation of a standard that would have value from a public health standpoint: the "ODI" or "Optimum Daily Intake" When he killed himself last year, we lost one of the best champions of health freedom we've ever had. Since he is not here to defend himself, I ask that you frame your points based strictly on any argument you may have against what he has specifically written.

Comment especially on the following please:

Vitamin D
Vitamin A

If you answer yes to any of these, could you tell me what you think the maximum safe dose is?

Should there be maximum limits set for cadmium in peanuts?

These quesions aren't relevant to Leibovitz article. Leibovitz never said there should never be limits set on a basis of sound risk assessment, he just didn't consider Hathcock's methods to be legitimate and I share his criticisms.

Secondly, do you accept that Pauling and McBride fudged any of there results? If so, does that undo all of the excellent work they did regarding vitamin C and Thalidomide respectively?

State your exact question and I'll consider it providing you relate it specifically to Leibovitz article. Leibovitz did not discuss Thalidomide or Pauling.

Look forward to your responses

Kind regards


JON 3(2), 1994
Brian Leibovitz, Ph.D.

Acronyms, b-Carotene, And Capsaicin


One of the Bad Science (BS) Award candidates this issue is John Hathcock, Ph.D., Office of Special Nutritionals, Center for Food Safety and Applied Nutrition, FDA. The reason? He is the sole author of a paper that, to the best of my knowledge, introduced the most absurd acronyms and ridiculous equations in a single article (1). This is true with respect to both quantity and quality.

This paper, published in Nutrition Reviews, introduced novel acronyms as well as toxicology acronyms adapted for nutrition:

ADI (acceptable daily intake)
SF (safety factor)
NOAEL (no-observed-adverse effect level)
LOAEL (lowest-observed-adverse effect level)
RfD (a reference dose that "probably will not cause deleterious effects over a lifetime of exposure")
UFs (uncertainty factors)
MF (modifying factor)
SI (nutrient safety index)
SL (safety limit)

Hathcock's definitions and calculations were equally unenlightening and senseless - not to mention confusing:

"For calculation of the RfD, the SF has been refined into multiple components described as uncertainty factors, UFs, and a modifying factor, MF. Thus, the RfD is defined by the following equation: RfD = NOAEL (or LOAEL) / (UF x MF), where UF represents one or the product of several uncertainty factors [emphasis added], generally tenfold each. An additional factor, the MF, is used as necessary to account for areas of uncertainty that are not explicitly addressed by the usual factors [emphasis added]."

"To assess the comparative safety of nutrients, a nutrient safety index (SI) has been defined as a ratio that is analogous in several ways to the therapeutic index (TI) for drugs. The SI was defined as the minimum toxic dose divided by the recommenced intake: SI = LOAEL / RI. This SI is useful for comparing the relative hazard posed by overconsumption of different nutrients. In this analysis, an SI of 10 does not indicate that an intake of up to 10 times the RDA is safe. Instead, it indicates that such an intake provides no margin of safety [emphasis added]." "If appropriate and adequate human data are available, a safety limit (SL) could be calculated as follows: SL = LOAEL / SF where LOAEL is the lowest-observed-adverse-effect level derived from clinical reports and SF is a safety factor that provides an acceptable margin of safety. The SF could be either fixed or variable [emphasis added]."

"Safety limits may be calculated by the SRM [square-root method] and MPM [midpoint method] as follows: Midpoint method:

SL = (LOAEL - (LOAEL - RDA) /2)) or equivalently
SL = (LOAEL + RDA) divided by 2 x (the arithmetic mean)
Square-root method:
SL = (LOAEL / SF) = LOAEL / SI0.5
where SI = LOAEL / RDA
or equivalently
SL = (LOAEL x RDA)0.5 (the geometric mean)."

"The confidence in and reasonableness of safety limits, regardless of the method used to define them, will be enhanced if the objectives [emphasis added], data criteria, and the quantitative method have been agreed upon ahead of time by groups responsible for nutrition and health policy [emphasis added]."

The scientific translation: agree on the policy (results) prior to conducting the research. Furthermore, why should "groups responsible for nutrition and health policy" - not bonafide nutritional scientists - be the final arbiters of scientific truth?