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Date: Sat, 05 Sep 1998 22:55:15 -0400
From: John Hammell <>

At 02:33 AM 9/6/98 EDT, you wrote:
>I am confused - mabey you can clarify something for me.  The letter which
>opposes the proposed FDA rule that we are urgently being asked to sign and
>send is being supported by CFH and now I have read your negative comments on
>this organization. How do these two go together, what am I missing.  I'm
>if I sound stupid.  I really do care about this issue and want to do the
>thing.  You are amazing with all the information I am finding on your web
>sight.  I just discovered it tonight.            Please respond ASAP.  I know
>you're busy - keep up the incredible work!

Tracy and EVERYONE: My form letter (at end) combines three related issues,
while Citizens for Health (controlled opposition)is not fighting back the
way they should- they are "pulling punches" and this mssg explains why.
(When a boxer is trying to "throw" a fight, he "pulls" punches, in order to
get kickbacks, usually from organized crime. Well, as far as I'm concerned,
the pharmaceutical industry = organized crime, and unfortunately, they have
their tentacles deep inside the dietary supplement industry, and if you
read this you'll glean much SPECIFIC insight.)

My form letter (at end) simultaneously addresses these 3 heavily
intertwined issues:

1. FDA's proposed rule.
2. HR 2868 the Consumer Health Free Speech Act
3. A request that Dr.Yetley of FDA call for the Complete Withdrawal of the
German Codex proposal at the upcoming Codex meeting in Berlin Sept. 21-25th.

Citizens for Health is not behind HR 2868, which would solve the problem we
are currently faced with due to FDA's proposed rule which threatens to
attack dietary supplements as "unapproved drugs" based on intended use. HR
2868 would stop FDA from placing unconstitutional limits on commercial free
speech, its a very simple bill which cuts straight to the heart of the
problem: the current, overly broad definition of "Drug" which is so broad
that it includes FOOD.

Well, we all know that foods are not drugs, right? I mean, just because a
substance has therapeutic properties, that doesn't make it a drug.
Something should only be considered a drug based on its toxicity,
carcinogenicity, mutagenicity, and teratogenicity--- otherwise, even WATER
could be considered to be a "drug" since it certainly has therapeutic
properties. The fact is that foods (including most herbs) seldom have a
toxic effect when compared to drugs, which often do.

So, WHY isn't Citizens for Health behind HR 2868? They give "reasons" like
"it would open up DSHEA", and "we don't like the way its worded", which is
absurd. They were also against HR 1951 a couple years ago even though it
would have plugged the gaping holes in DSHEA, which brought us the
Commission on Dietary Supplement Labels, whose final report set up FDA's
current proposed rule from hell, are you beginning to follow me?

Now, WHY wouldn't CFH be for HR 2868? Here, we get into the internal
politics of the dietary supplement industry, a murky area into which most
consumers never see, which makes people vulnerable to manipulation by some
powerful vested interests. Sadly, the pharmaceutical industry has gotten
their greedy meathooks deeply into our industry, but the average consumer
doesn't see whats going on, and, sadly, most health food store owners are
equally unaware of how they are being manipulated, even by their own trade

On September 1, CNN ran an article which I recently downloaded from  The article is titled
"Study: More doctors learning alternative medicine, but safety still
questioned" and it was by Al Hinman. The article extols the alleged virtue
of the German regulatory model, and urges its adoption here in the USA. It
quotes a spokesman for Schwabe International, a German Phytopharmaceutical
Company saying "many of the leading prescribed products are indeed natural
products" and it says "Schwabe International' variety of natural medicines
are shipped around the world. But on U.S. shelves, their pills are up
against competitors that don't need to meet the same standards for potency
and quality."

Its very important for you to realize that Schwabe International has an
American partner, an herb company based in Springville, Utah called
Nature's Way. Nature's Way also has another German partner called Madaus
AG. These 3 companies are part of the European American Phytomedicines
Coalition, which has been petitioning the FDA since 1992 to regulate herbs
as "Drugs". Nature's Way is certified by the FDA as an OTC drug
manufacturing facility.

In their advertising, Nature's Way has claimed a lot of credit for pushing
DSHEA through Congress, and they also pride themselves in their close
association with Citizens for Health. CFH's executive director, Susan
Haeger, takes her marching orders from Loren Israelson, who is the attorney
for Nature's Way, and also co counsel to the European American
Phytomedicines Coalition-- the folks who are so busy petitioning FDA to
regulate herbs as "Drugs". (I have a stack of documents nearly 2" thick
which EAPC has submitted to FDA since '92 for that purpose.)

I just sent a letter out to this email list which was from those documents,
which are on public file at FDA. The letter was from the German embassy to
the FDA and was written on behalf of the EAPC, and called for herbs to be
regulated as "drugs".

Why does So Called "Citizens for Health" oppose HR 2868? The reason is very
simple. It would be a conflict of interest to the EAPC if they did because
it would create a level playing field: it would allow therapeutic claims to
be made on dietary supplements, and Nature's Way and EAPC don't seem to
want that. They seem to want to dominate the N.American industry, and to
drive smaller competitors out of business by raising the hurdles to full
pharmaceutical standards. There are many good, smaller herb companies which
sell whole herbal formulas.

Christopher Enterprises is one such company. It was started by the late
master herbalist, John Christopher, a very unselfish soul who believed in
the healing power of herbs and who wanted the masses to learn how to use
them. He had a very successful clinic in Salt Lake City, and helped so many
people with serious ailments to heal that the local allopathic doctors had
him put in prison for "practicing medicine without a license." After he got
out of jail, rather than restart his clinic, instead he established the
School of Natural Healing, and Christopher Enterprises, whose whole herbal
formulas have stood the test of time, and are fairly priced.

When Nature's Way was started, they had a licensing agreement to use
Christophers Formulas, but they started altering the formulas when they
became partners with Madaus AG and Schwabe as they "standardized" them.
Recently they reneged on their licensing agreement with Christopher
Enterprises. It seems to many people that they may have been less than fair
in so doing.

It disturbs me on a deeply personal level that in both the USA and in
Canada, Nature's Way is trying to turn herbs into "Drugs". I can prove this
because I have been active on both sides of the border through my work, and
know many people in Canada. In Canada, they have not lifted a finger to
support the "Foods are Not Drugs Amendment" sponsored by Grant Hill, a
member of parliament who is fighting for health freedom, and down here,
they are opposed to HR 2868, for the same reasons, they seem to oppose a
level playing field.

I could go on, I could type for a couple of hours to tell you the whole
story because theres a lot, lot more to all of this, but I hope this gives
you the gist of the situation. I have compiled a lot of evidence over the
years that Citizens for Health is being used as front by the EAPC.

It would help you a lot to more fully grasp whats going on if you read this

The title is The European Phytomedicines Market:Figures, Trends, Analyses,
by Jorg Grunwald.
Grunwald is a consultant to the German Phytopharmaceutical Industry, and he
matter of factly sizes up the world market for herbal medicines in economic
terms. His article includes in table 6 a list of multinational
pharmaceutical giants which have bought up phytopharmaceutical companies,
illustrating the pattern of "roll up" by which the pharmaceutical industry
is getting their tentacles into our industry. These companies want to grab
market share by pushing all the small herb companies out of business, and
the way they try to do that is by trying to cut deals with regulatory
bodies such as FDA, all over the world. They can't be trusted. They aren't
for the consumer. They want to maximize their profits by selling herbs as
"Drugs". CFH has opposed my efforts to stop American and Canadian Food and
Drug Laws from being "harmonized" to EEC 65/65, the European Commission
Directive to which the drug cartel is attempting to enslave us.

I hope this helps. IAHF has been painstakingly working with true grass
roots health freedom organizations world wide to try to expose and stop
this scam from unfolding. If you appreciate our work, please consider
sending a donation. I need money to get to Berlin for the upcoming Codex
meeting. I'm on the US delegation, but the government doesn't pay the way
for NGO observers on the delegation. I have attended a previous Codex
meeting in Bonn, Germany where I witnessed the Codex Shell Game first hand
and have been successful to some degree over the past few years in
monkeywrenching their nefarious plans by knowing when and where to stick
the wrench into the cogs of the machine. Ours is a true grass roots
undertaking, made possible by the power of the internet.
Thank you for your heart felt interest in health freedom issues.



Dear Dietary Supplement Consumer:

 We have flooded the FDA with so many comments against their proposed rule
to block your access to truthful health information on the labels of
dietary supplements, that they have extended their comments period an extra
month until September 27th, 1998. It is of critical importance that we keep
the pressure on, right up until the deadline! The form letter below fully
explains this situation, as well as another which we must also protest! The
German Codex proposal which threatens to internationally limit consumers to
untherapeutic potencies of vitamins and minerals, as well as to regulate
any dietary supplement not having an RDA as a “drug” threatens to advance,
once again, at the upcoming Codex meeting in Berlin from September 21-25th.
Beth Yetley, Ph.D. and Robert Moore, Ph.D, of the FDA will represent
America at this meeting. An inside the beltway pressure group called
“Center for Science in the Public Interest” has submitted comments to the
FDA in an effort to pressure them to stop opposing the German Codex
proposal, alleging falsely that dietary supplements are “dangerous” to
consumers. CSPI is urging the FDA to exploit several loopholes existing in
DSHEA, claiming that they allow FDA to back the German Codex proposal.
These loopholes require us to ask Congress to pass HR 2868, so cc the form
letter to your Congressman. It is imperative that we bury the FDA with
complaints about CSPI’s comments, and that we insist that the FDA demand
the complete withdrawal of the German Codex proposal which diametrically
opposes our domestic policy regarding access to dietary supplements. For
more information on how you can help carry this warning to consumers all
over the world, please visit the IAHF website at, email us at, for more info call 800-333-2553.  (Get in to FDA by Sept.
19, if possible, Sept. 27th at latest.)
cut------------------------cut here--------------------cut
Submit comments to: Dockets Management Branch (HFA 305) FDA, 200 C. St. SW,
Washington, DC 20204 (email or fax 301/827-6870)
Re: (Docket # 98 N-044) RIN 0910-AA59 Regulations on Statements Made for
Dietary Supplements Concerning the Effect of the Product on the Structure
or Function of the Body/   email to Dr.Yetley

To: FDA Dockets Management Branch & Beth Yetley, Ph.D., Robert Moore,
Ph.D., US Codex Delegates:

Your Proposed Rule on dietary supplement labeling will have an adverse
effect on public health by placing arbitrary and capricious limits on the
allowable health information that can be presented to consumers at the
point of sale on dietary supplements, in compliance with the First
Amendment. Your definition of disease is overly broad, and you are clearly
over reaching. In your zeal to “insure that dietary supplements don’t act
as a disincentive to new drug development” (Gary Dykstra, FDA), you would
even disallow structure-function claims relative to aging: i.e.: “hot
flashes” (since when are aging or menopause “disease states”?)

In the US District Court in Utah, Judge Dale Kimball just issued an
injunction against the FDA forcing you to lift your ban on cholestin, which
he declared was a dietary supplement under DSHEA. You tried to ban this
safe Chinese red rice yeast extract which helps lower cholesterol because
its sale angers pharmaceutical giant Merck. We remind you that dietary
supplements were specifically exempted from the harmonization language in
the FDA Reform Bill and that Congress was flooded with faxes, email, and
outraged calls on this issue as recently as October, 1997. Prior to that,
in 1994, Congress received more mail on this issue than on anything since
the Vietnam war. For the sake of the public health, we strongly urge you to
change the proposed rule and stop blurring the distinction between disease
and a health condition. ADDITIONALLY: I request that you forward this
message to Dr.s Yetley and Moore at FDA Office of Special Nutritionals
(CFSAN) to inform them that at the CODEX meeting in Berlin (September
21-25), I INSIST that they demand the complete withdrawal of the German
Codex Proposal which diametrically opposes US law, and which threatens the
public health world wide.

cc to my Congressman in support of HR 2868, Consumer Health Free Speech
Act- removes food from the overly broad statutory definition of a drug-
allowing for therapeutic claims, as long as they are true.



City:____________________________________State:_____ Zip:____________________

Am On the US Codex Delegation, But the Gov.
Doesn't Pay Our Way for NGO Observers
If YOU Want the Shell Game Monitored-
Kindly Help Met To Defend YOUR Access to
Send Check or MO in US $ to:
John C. Hammell, legislative advocate
IAHF 2411 Monroe St.
Hollywood, Florida 33020 USA
800-333-2553, 954-929-2905 outside USA, fax 954-929-0507