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Category: ArticlesCodex

Here We Go Once Again
By Bill Sardi
June 29, 2013


            In 2002, I wrote a letter to the US representative to CODEX, that worldwide body established by the Food and Agriculture Organization of The United Nations and the World Health Organization to develop international food standards and guidelines and “ensure fair practices in the food trade.”

            I opposed planned CODEX harmonization of doses of vitamins and minerals on various grounds at the time, which I will reiterate and expand upon here in this monograph. I also opposed efforts to set upper dosage limits in 2005.

            The public may not fully grasp all the science in this dispute, but they do get the idea that some entity outside the control of elected officials here in the USA is going to determine just how much nutrition is good for them, and it doesn’t like that.

            Someone has said politicians and regulatory agencies had better not mess with Americans over three issues:  guns, privacy in their bedroom, and freedom to purchase dietary supplements. That was demonstrated in 1994 when the Dietary Supplement Health and Education Act was reluctantly passed when public uproar sent more letters to Congress in favor of that legislation than any other issue on record.

            CODEX, feeling public pressure, tabled its efforts to harmonize the amount of vitamins and minerals in dietary supplements for over a decade now.  The public had been aroused and CODEX couldn’t move forward because of the political fallout.

            Now CODEX wants to reconvene to reconsider its plan for harmonization and its leaders are gauging whether there is sufficient consensus (or sufficient votes, if need be) among its delegates to get the job done this time. 

            However, health-freedom advocates have formed loose alliances and recently staged a worldwide event opposing genetically modified foods (GMO) in 400 cities worldwide, so regulatory bodies like CODEX may not be invulnerable to mass public opposition.

            A problem exists in instructing the public how to oppose CODEX requirements over vitamins and minerals, as CODEX is not an elected but rather an appointed body.

            Currently, the Codex Alimentarius Commission has 186 Codex Members, 185 Member Countries, and 220 Codex Observers.

Direct Influence on the CODEX Commission

            The only way to apply direct pressure is to work with US-based National Health Federation (NHF), which is an official, accredited delegate to CODEX, and to stay abreast of this issue by getting on the NHF mailing list.

            There are other self-appointed health-freedom organizations that are grand-standing the CODEX issue and falsely claim donations will help them fight CODEX, but they are not in position to do anything beyond their own presence on the internet.  They dilute the message that the NHF needs as a strong voice for health freedom at the CODEX meetings.

            The link to the NHF website is www.thenhf.com  Scott Tips is a recognized food-and-drug attorney who captains the NHF and delivers influential speeches directly to the delegates at the CODEX commission when it convenes.

            The NHF indicates indirect public pressure needs to be applied to CODEX’s point person regarding its current anti-supplement agenda.  That person is nutritionist Janine Lewis who heads the Australian CODEX delegation.  Lewis posts an online presentation of proposed nutrient recommendations that would reduce 11 of 14 essential vitamins and minerals compared to the currently used Daily Value/Reference Daily Intake.  CODEX meets in Rome, Italy from July 1-5, 2013, and then again in early November 2013 in Germany.  Specific points of opposition are provided in this report.


Ms Janine Lewis – Principal Nutritionist – Food Standards Australia New Zealand – P.O. Box 7186 – Canberra BC ACT 26110 Australia

Tel.: +61 (2) 62 71 22 45

Fax: +61 (2) 62 71 22 78

E-Mail: janine.lewis@foodstandards.gov.au

Why we should be concerned about CODEX

Understanding How CODEX Operates

            Consumers of dietary supplements need to understand how big business thinks and why it is behind the harmonization efforts of CODEX.

            What multinational companies do is create standards organizations under the guise of consumer protection as a false front for their strategic marketing efforts.

            Thanks largely to the internet, we know more today how the World operates than we did a decade ago when CODEX became an issue for dietary-supplement advocates.

            We recognize today it is not freedom and democracy that is being spread to the 196 sovereign nations around the World (193 that belong to the United Nations), it is fascism.  This is not the jack-boot fascism seen in Italy under Mussolini in WWII.  It is a more covert form of fascism where commercial forces buy-off elected officials to control populations.

            If you think I am sounding a bit too conspiratorial, investigate this on your own.  Recently, the non-political Public Library of Science journal (PLos ONE) published an authoritative report showing that a small nexus of banks and corporations control world affairs.

Harmonization Benefits Multinational Companies, Not Necessarily Consumers

            It is more convenient for multinational corporations to promote international standards.  Then they don’t have to match specifications for each and every country to market their products.

            The hidden driving force behind harmonization lies in demolishing competition by establishing onerous manufacturing, safety, and health reporting requirements that only large corporations can achieve and then eliminate the cost of marketing and advertising products in the open market by influencing governments to mandate them.  An example is mandated vaccination.

            Over the past few decades we observed in California an onerous requirement to build double-walled tanks to store underground gasoline, a law that drove independent gas stations out of business and resulted in reduced price competition.

            Another more recent example was a failed effort to pass a burdensome paperwork requirement on food outlets that market GMO foods, thus giving advantage to large multi-national companies.  Advocates of non-GMO foods would have unwittingly voted for a regulation that would be impossible for small food stores and family farmers, who don’t grow GMO foods, to comply with. The trick almost worked.

            Recognize greater Los Angeles had extensive public transportation in the 1940s and 1950s and the auto industry lobbied to eliminate the electric cable cars (“red cars”) in order to sell more automobiles. This is how big business thinks – strategically, to rig markets in their favor.

            Yet another example is natural gas-powered automobiles and filling stations that would cut fuel prices by more than half.  The U.S. now has a glut of natural gas with its fracking operations for oil.  All the U.S. Congress need do is pass tax-incentive legislation to expand the number of natural gas filling stations nationwide and consumers would save hundreds of billions in fuel costs annually.  Autos would then be built with natural gas engines to meet demand.  But that isn’t happening because Congress is bought off.

            I hope I don’t sound too off topic here, but readers need to see what is happening on a larger scale to understand the CODEX threat.

A Real Example

            Allow me to digress again, only this time with a more pertinent example that involves dietary supplements.  I have a first-person experience how Big Pharma and modern medicine deals with competitive threat.  I captain a company that makes a red-wine resveratrol (rez-vair-a-trol) pill, heralded as an anti-aging pill, so I can offer an inside view of the roadblocks Big Pharma throws in the way.

            While there are 432 listed brands of resveratrol pills, the product we make is the best tested.  It was shown to abolish the first sign of blood vessel disease in humans, turn mortal heart attacks into non-mortal events in the animal lab, and is reported to quell treatment-resistant blindness among otherwise hopeless patients.  So it is the point product for this category of dietary supplement.

            Covert opposition to this pill by Big Pharma is not easily recognized. Efforts to dampen consumer enthusiasm for resveratrol pills have been successful.  If the public only knew of the great promise of these red-wine pills, they would out-sell any drug including Viagra by billions of dollars. 

            Laboratory researchers have intentionally overdosed animals with resveratrol to produce negative results.  They even overdosed terminal cancer patients who rapidly developed kidney failure in an effort to quash the promise of this pill as a cancer cure.  A leading resveratrol researcher was falsely accused of scientific fraud for cooperating with the small dietary-supplement company I manage.  Big Pharma also blocked an approved NIH trial for Alzheimer’s disease using our product.  In another lab experiment, tissue samples were destroyed.  Five years ago, eye physicians knew our product rescued helpless patients from the throws of blindness when conventional drugs failed to work, but elected to hide this fact, a decision that resulted in 150,000 people needlessly going blind.

            In the eight years since resveratrol pills became widely available, not a single human clinical trial has ensued to put it to the test for heart health, which was its original promise as a “red wine pill.”

            Then, a European researcher organized a worldwide symposium of resveratrol researchers along with manufacturers of resveratrol-based products.  The symposium had a hidden agenda -- to call for resveratrol to be a drug rather than a dietary supplement.

            Later, the company I captain received an unsigned letter on a major university’s letterhead that if our company continued to come to the defense of the falsely accused researcher, that efforts would be made by the research community to put our company out of business. (Authorities and news reporters have viewed this letter.  I am not contriving up some self-hatched scheme for commercial purposes here.)

            Few recognize the threat that resveratrol poses for Big Pharma, as it has broad biological action that would replace most prescription drugs.

            What I am telling you is the CODEX issue is not a battle between seemingly eccentric and uninformed vitamin fanatics pitted against agencies that pretend to protect the public from vitamin and mineral overdoses.  This is a battle against entrenched forces who threaten to limit access to nutrients that our very lives and health depend upon.

Disease Mongering

            Few readers fully recognize how the masses are being gamed so they only obtain paltry amounts of essential nutrients that ensure a certain level of disease in human populations for doctors to treat and prescribe.

            The best example is Vitamin D that holds promise to lower the mortality rate in the World.

            This is a vitamin that was discovered in 1922 and over 90 years later its important and irreplaceable role in health promotion is just now being realized.  (Isn’t that evidence of foot dragging?) 

            Big Pharma stands ready to introduce six synthetic drug versions of Vitamin D and rig clinical studies to show these vitamin-like drugs are superior to what nature provides via dietary supplements. 

            Based upon the best available evidence we have today, human populations that achieve Vitamin-D adequacy will likely suffer less severe heart failure, fewer infections, less mental depression, better control over blood sugar, better muscle tone and will live longer.  Just as sunlight is feared by Dracula, health promotion is loathed by the pharmaceutical industry.  It is in the business of treating disease, not keeping people healthy.

Self Dealing

            The US population is oblivious to this self-dealing in medicine.  For example, the mortal form of melanoma was not prevalent until sunscreens came into common practice over false fears that ultraviolet sun rays induced this form of skin cancer.  But sunscreens block the Vitamin-D producing UV-B rays, which vitamin is an anti-cancer agent, while allowing the deeper penetrating UV-A rays to prematurely age the skin unopposed.  The fear over deadly skin cancer drove concerned patients to dermatologists’ offices.  But the mortality rate for skin cancer rose.  In the name of prevention, modern medicine kills.  UVA exposure is associated with mortality due to skin cancer.  Heart failure rates also tripled with the use of sunscreens.  Sadly, the public phobia over solar UV skin exposure is now ingrained.

                  The net effect is the cost of Vitamin-D insufficiency due to lack of sunlight and under-dosed Vitamin-D supplements rose to an estimated $40-56 billion (2004), while the cost of caring for skin cancer induced by UV radiation is estimated at $6-7 billion. The cost of providing 1000 international units of Vitamin D daily for all adult Americans would run about $1 billion/year.  Modern medicine knows billions of dollars would be taken out of the pockets of doctors and drug companies if the recommended daily amount of Vitamin D should be raised to ensure adequacy of this essential vitamin.

General Criticisms of the CODEX Dosage Recommendations for Vitamins and Minerals

            My general criticisms are:

            1. The CODEX recommendations are archaic.  The published data to substantiate the adoption of CODEX dosage recommendations are outdated.  A whole decade has passed since these recommendations were first published and considerable change in dosage from CODEX is now recommended for Vitamin C, Vitamin D, Vitamin B1 (thiamin), zinc, and other nutrients.

            2. The establishment of a daily nutrient intake recommendation may result in dietary supplements that essentially are all the same.  Doses exceeding the CODEX recommendation are likely to be posed as potentially toxic when in fact, even the proposed safe upper dose is usually ten times lower than a dose that first begins to produce side effects. Harmonization may mean no consumer choice.

            3. The criticism still stands -- there are too many environmental, geographic, hereditary, and genetic differences in human populations to agree upon a one-dose-for-all standard. For example, people living at northern latitudes with dark skin pigmentation require ten times more sunlight to achieve the same blood levels of Vitamin D as Caucasians.  Only higher-dose Vitamin-D supplements can help dark-skinned individuals achieve the same blood levels.  Asians have an inherent genetic need for more Vitamin C that a harmonized supplement may not address.  That’s a ditto for a third of the human population that has a genetic inability to metabolize folic acid, a B vitamin that is required for DNA repair.

            4. Establishment of a recommended daily intake for essential vitamins and minerals serves to mislead consumers they consume sufficient amounts of nutrients to maintain health when in reality that is far from the truth.
The CODEX recommendations do not address real-world situations. The hidden asterisk is that these vitamin-and-mineral intake levels are established for healthy adults, not for growing children, pregnant females, diabetics, smokers, athletes, the hospitalized, individuals with chronic infection (hepatitis, HIV), older adults who do not secrete adequate amounts of stomach acid and therefore do not adequately absorb essential nutrients, or individuals who suffer nutrient depletion from prescription drugs, or those with known genetic flaws that increase nutrient requirements.

            5. While the CODEX monograph does address varying degrees of vitamin-and-mineral absorption as a physiologic factor, there are large differences in oral absorption dependent on the type of each vitamin and mineral, a factor that is not adequately addressed by CODEX. For example, only 4% of magnesium oxide is absorbed and cannot possibly be equivalent to other forms of this mineral in dietary supplements.  Zinc methionine is far better absorbed than other forms of this trace mineral.  An equal dose of a nutrient like zinc or magnesium on two separate dietary supplement labels may have an entirely different effect based upon inherent absorption of the nutrient.

            6.  There are dietary practices and health habits that interfere with nutrient absorption or that increase the need for certain nutrients that are not addressed in the CODEX proposals.  For example, smoking depletes Vitamin C.  There are large differences in smoking rates between countries.  In some countries per-capita cigarette use is less than 1 per month while in others it is nearly 8 per day (240/month).  An estimated 51% of males in China smoke cigarettes, 42% in Japan, whereas only 26% smoke in India, which would influence the adequacy of Vitamin-C supplementation.  About 25 mg of Vitamin C is depleted per cigarette smoked. 

            Over 1 billion people adhere to religious dress codes that block sun/skin exposure that results in prevalent Vitamin-D deficiencies that may not be addressed by standard one-dose-fits all supplementation.
Western populations that consume large amounts of refined sugar, tea, coffee, and alcohol suffer from a wide array of misdiagnosed symptoms (frequent bowel movements, fibromyalgia, nerve problems) associated with the fact these dietary components block the absorption of thiamin (Vitamin B1).  Common water-soluble Vitamin B1 (thiamin) may not be adequately absorbed and fat-soluble Vitamin B1 (benfotiamine) may be required.

            7.  How can CODEX’s recommendations further resolve large undetected nutrient deficiencies in human populations when the CODEX proposals reduce rather than increase the dosage of 11 of 14 selected vitamins and minerals? 
For example, the current Recommended Daily Allowance (RDA) for zinc for adults ranges from 8 to 11 milligrams. The Recommended Nutrient Intakes (RNIs) for dietary zinc (mg/day) proposed by CODEX to meet the normative storage requirements from diets differing in zinc bio-availability for adults 12 milligrams.  The current Daily Value utilized by dietary-supplement companies calls for 15 mg of daily zinc.  Yet zinc deficiency is rampant, affecting over 2 billion humans, and CODEX proposes to reduce the recommended amount in dietary supplements by twenty percent.

            The Recommended Daily Allowance (RDA) for Vitamin C is 60 mg.  The CODEX Recommended Nutrient Intake for Vitamin C is just 45 mg.  CODEX proposes to reduce provision of Vitamin C at a time when health authorities recognize scurvy (frank Vitamin-C deficiency) still affects millions in developed nations.

            8. It appears the CODEX nutrient requirements may be based on flawed reasoning, which is a common practice throughout medicine.
The Recommended Nutrient Intake (RNI) proposed in the CODEX monograph is the basis for the Nutrient Reference Values (NRV) mentioned throughout CODEX documents.  CODEX states “NRVs are based on levels of nutrients associated with nutrient requirement, or with the reduction in the risk of non-communicable diseases.”  It doesn’t say which criteria (“nutrient requirement” or “diseases”) served to develop the NRI or NRV for specific nutrients.
Incidentally, if a nutrient is deemed to prevent, treat, or cure any disease in the USA, it is reclassified as a drug, so to utilize criteria that involve “risk reduction of disease” appears to be outside the definition of a dietary supplement.
So-called reference values for nutrients generally refer to commonly occurring values, not necessarily values that have been determined to maintain health.  
In other words, if an entire population has low blood concentrations of a particular nutrient (the reference range) and an individual is below that value, all it means is that they have poorer nutrition than the reference group, but the reference group may be entirely deficient and experience symptoms.  An example might be Vitamin C, which due to a universal gene mutation has blocked internal liver synthesis of this essential vitamin in Homo Sapiens versus other species of animals. Compared to animals that do internally synthesize Vitamin C, all of humanity is deficient.

            Whole populations of religious groups who cover their skin with clothing and have lower Vitamin-D levels due to lack of sun exposure would be another example of a reference group that is almost totally deficient.  It is common to compare blood levels of nutrients against the “normal reference range,” but this comparison is misleading and meaningless.  A specific blood concentration, to be meaningful, needs to be compared against the “healthy range.”  The healthy range may be different than the range that “reduces risk for non-communicable diseases.”  For example, a person may be low in Vitamin B12 and experience symptoms of fatigue, short-term-memory loss, sore tongue, burning feet, all which are characteristic symptoms of low B12, but be free of disease (pernicious anemia) which produces nerve damage and gastric polyps.

            Furthermore, it is one thing if an individual is generally healthy (without symptoms induced by a deficiency) and discovers their nutrient levels are outside the normal reference range and completely another thing if they are ill and experiencing symptoms of deficiency disease that may require a stronger loading dose to rapidly achieve nutrient adequacy.

            The Recommended Daily Intake (RDI) is closer to a nutrient standard that represents a “healthy range.”  The RDI is explained as: "the levels of intake of essential nutrients considered adequate to meet the known nutritional needs of practically all healthy people. RDIs exceed the actual nutrient requirements of practically all healthy persons.”

            While the RDI may exceed nutrient requirements for all healthy persons, it obviously doesn’t pertain to large portions of human populations addressed in point #3 in this document (people who have greater need due to chronic illness, stress, growth, etc.).  So, the RDIs exceed the RNI and the NRV ascribed to by CODEX, which is an open admission that the RNI and NRV do not even come close to adequately addressing the nutrient needs of large portions of human populations in the real World.

            (By the way, the RDI is intended for assessment of individuals; but is not intended for use to assess intake levels for groups.)  It seems the RNI and NRV by definition are patently misleading and represent a watering down of current nutrient values (Recommended Daily Allowance) employed in the USA for labeling purposes.  Consumers are going to use the CODEX RNI to address their individual needs when it is based upon the needs of a population as a whole and is not intended for personal assessment.  Essentially CODEX is “pulling the wool over the public’s eyes.”

            9.  CODEX addresses the need for vitamins and minerals by age but not by physiologic need and stage of life. For instance, during childhood growth the need for iron and calcium to facilitate mineralization of bone and formation of red blood cells is high.  The need for these minerals wanes after full growth is achieved in males and after the onset of menopause and child-bearing in females.  Provision of supplemental iron and calcium for full-grown males may be deleterious, yet the CODEX recommended daily intake level does not change.  This represents a major flaw in establishment of the RNIs.

            10.  There is no mention of therapeutic dosing despite the fact mega-doses of certain vitamins have been demonstrated to have a therapeutic (curative) effect. CODEX and modern medicine continue to cast a blind eye at safe therapeutic applications of vitamins and minerals.  For example, a 3-gram/day (3000 mg) dose of oral Vitamin C has been demonstrated to favorably control blood sugar among diabetics. A 1000-mg oral dose of Vitamin C has been demonstrated to reduce circulating histamine levels without fail and may be efficacious for individuals during acute allergy attacks.  A 2000 mg dose of oral Vitamin C has been shown to reduce histamine levels by 38%. 
In 2008, it was conclusively demonstrated that a 5000 mg repeated mega-dose of oral Vitamin C can achieve blood concentrations sufficient to transiently product hydrogen peroxide (H2O2) that selectively kills cancer cells, reduced tumor size by 50% (the standard required by FDA for an approved anti-cancer drug), and then converts to harmless water (H2O).  While there are warnings issued that mega-dose Vitamin C induces diarrhea or kidney stones, these side effects were not reported.

            The dose limitation of Vitamin C pills proposed by CODEX complicates safe, self-care regimens and limits patient choice.  Given there are no proven cures for cancer from allopathic medicine, the failure of CODEX to recognize therapeutic applications for dietary supplements is a glaring oversight.  The so-called tolerable upper limit for Vitamin C is 2000 mg per day, which many consumers exceed without reported side effect.  CODEX’s daily Recommended Nutrient Intake (RNI) for Vitamin C is just 45 milligrams. Should makers of Vitamin C pills choose to reduce daily dosage of Vitamin C to this paltry level given the false assurance it represents 100% of the RNI, individuals who choose to consume a therapeutic dose of Vitamin C (1000-3000 mg) would have to take 22-to-66 of the 45-mg pills to achieve this dosage.

            In spite of the U.S. Food and Nutrition Board establishment of a daily dietary requirement for Vitamin C at 75-90 mg per day for adults and only 125 mg per day for smokers, private enterprise has responded to consumers and it is difficult to find Vitamin-C pills in doses less than 500 mg. Industry has ignored the Food and Nutrition Board’s nonsense.  It should also ignore CODEX.  In this instance, the free market established the dose-per-pill for Vitamin C without harming consumers. 

Brief comment on proposed CODEX Recommended Nutrient Intake by selected individual nutrients:

Vitamin C:  The 45 mg CODEX recommendation for Vitamin-C intake does not even raise blood levels significantly.  The reduction of Vitamin-C recommendation is inexplicable in the World when an estimated 1 billion people still smoke cigarettes (25 mg of Vitamin C is depleted for each cigarette smoked).  The criticism that Vitamin C is rapidly excreted and Vitamin-C pills just create expensive urine only point to greater need for supplementation throughout the day. Despite claims to the contrary, the only Vitamin-C sufficient humans on the planet are supplement users.  Others may not have frank symptoms of scurvy (hemorrhage, irritability, anemia, infection), but they suffer allergies, rupture of calcium plaque that triggers sudden mortal heart attacks, asthma, Reyes syndrome, and gluten intolerance, which is now in vogue.

Vitamin B1 thiamin: Western countries are suffering a hidden plague of thiamin deficiency as frequent consumption of coffee, tea, beer, wine, and refined sugars block B1 absorption.  Modern medicine has redefined the plague of beri beri (thiamin deficiency), which is traditionally characterized by the three Ds (dementia, dermatitis and diarrhea) into modern diagnoses of mental depression, irritable bowel, and fibromyalgia.  Only consumption of fat-soluble Vitamin B1 (benfotiamine) may resolve this modern plague.

Vitamin D:  The diet provides only a paltry amount of Vitamin D and sun-phobia has worsened the prevalence of this vitamin deficiency.  The RNI proposed by CODEX for Vitamin D will not significantly raise blood levels nor will the tolerable upper dose limit resolve a case of rickets in a young black child.