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Dr. Rath Health Foundation

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The Worst Is Still To Come

By Paul Anthony Taylor

November 2005 – November 2005 saw the 27th meeting of the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) take place in Bonn, Germany. The Committee, one of 27 currently active Codex committees, has been meeting in Germany since its inception in 1966, and was responsible for the drafting of the controversial Guidelines for Vitamin and Mineral Food Supplements. However, and as this article will show, the most potentially damaging aspects of the Committee's attacks on natural healthcare and health freedom are still to come.

The 2005 meeting of the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) took place from 21-25 November, in Bonn, Germany, and was attended by 315 delegates representing 68 countries and 33 international organizations.

Any doubts as to whether or not Codex is concerned about its loss of trust and respect amongst consumers were immediately dispelled by the Committee's infamous Chairman, Dr. Rolf Grossklaus, who opened the meeting by stating that the Committee had to improve its public relations image. However, any hopes that Codex might be about to change course proved to be wide of the mark when he went on to announce that the Food and Agriculture Organization of the United Nations (FAO), one of the two Codex parent bodies, would be filming this year's meeting, and explained that as a part of the film the FAO filmmakers would be interviewing some of the delegates. Clearly therefore we can expect to see a particularly propaganda-laden film becoming available for viewing on the Codex Alimentarius website in due course, complete with Codex delegates talking gushingly and disingenuously about 'protecting' consumers.

In addition, Dr. Grossklaus revealed that next year's CCNFSDU meeting will be taking place not in Germany, but in Thailand. Perhaps not surprisingly, therefore, some delegates subsequently speculated, privately, that this change in venue might in part be due to the adverse publicity that has been generated by the work of the Committee in recent years and that by holding their next meeting in Thailand, away from the public gaze, the Committee might be hoping to avoid further damaging scrutiny of its work.

Four items on the Committee's agenda this year were of particular importance to the future of natural healthcare and health freedom.

Proposals for Additional or Revised Nutrient Reference Values (NRVs) for labeling purposes

The proposal to consider additional or revised nutrient reference values (NRVs) for labeling purposes was originally made at the November 2003 meeting of the Committee, and this year the Codex delegates were considering a discussion paper prepared by a working group under the coordination of South Africa.

NRVs can essentially be thought of as a way of describing the nutritional requirements of the average person. Naturally however this concept presents an immediate problem, because, given that each of us is genetically unique, can it really be said that there is such a thing as an 'average' person? Moreover, in considering 'requirements' the fundamental question then arises as to whether one is talking about the nutritional requirements for ordinary health, or those for optimum health. As always, of course, the pro-pharmaceutical lobby can easily be distinguished in these discussions by virtue of their pressing for the NRVs to be set at, or near to, RDA levels.

The setting of the NRVs at realistic levels would be an important step towards the liberation of human health and the global recognition that dietary supplements are required for the optimum functioning of the human body. No small wonder then that the pro-pharmaceutical lobby is so vigorously opposed to the NRVs being raised to levels that can only be obtained via supplementation, as the concept of optimum health is inimical to the 'business with disease'.

Fortunately however the discussion paper prepared by South Africa showed clear evidence of support for the argument that the NRVs should reflect the most recent scientific research, in order to promote optimum health and reduce the risk of disease in the majority of people. Predictably, therefore, there was a good deal of controversy over this during the meeting, and the Committee's Chairman, Dr. Rolf Grossklaus, even went so far as to interrupt South Africa during their presentation, asking them to hurry up and finish.

Later on in the discussion, in a particularly partisan intervention, Dr. Grossklaus instructed the Committee that this was not about providing consumers with optimum nutrition, but about not misleading them and setting nutrient reference values for foods for global trade purposes. Nevertheless, and as the National Health Federation (NHF) delegation then quite logically pointed out, if the mandate of the Committee was really to avoid misleading consumers then there is most definitely a need to discuss optimum nutrition levels. Significantly however, NHF was the only non-governmental delegation representing the interests of health freedom at this meeting.

Towards the end of this discussion a representative of the FAO announced that along with the World Health Organization (WHO) they were about to hold a meeting in Florence, Italy, with the goal of reaching agreement on principles and guidelines that will lead to "evidence-based dietary standards".  As a part of this work FAO/WHO will apparently be discussing the possibility of setting up an expert consultation to establish new NRVs.

Clearly then, it would appear that the eventual setting of the NRVs will now be strongly influenced by FAO and WHO; two organizations with even less accountability to consumers than Codex itself.

Draft Recommendations on the Scientific Basis of Health Claims

The outcome of the Codex discussions regarding the Draft Recommendations on the Scientific Basis of Health Claims are absolutely crucial to the future of natural healthcare and health freedom, because, in order for chronic disease to become largely a thing of the past, dietary supplement manufacturers need to be able to provide truthful and non-misleading information about their products. Naturally therefore the pro-pharmaceutical lobby is becoming increasingly desperate to prevent the communication of lifesaving natural health information, as once this becomes sufficiently widespread it will essentially spell the beginning of the end for the 'business with disease'.

Nevertheless, and for the second year running, there was only a very limited opportunity for the Committee to consider the Recommendations at this year's meeting. Issues discussed during the short debate that did take place included authorization procedures for health claims, the scientific substantiation of health claims, and disease risk reduction claims.  There was no in-depth examination of these topics however, and the Committee agreed that this work would be continued over the next year by a working group under the coordination of France.

Crucially however the European Union (EU) is currently expected to adopt a very restrictive Regulation on Nutrition and Health Claims in mid-2006. As such it seems very likely that the EU will be pushing for the Draft Recommendations on the Scientific Basis of Health Claims to be given a much higher priority at next years CCNFSDU meeting in Thailand, at which point we can expect it to begin pressing for the Recommendations to be drafted in such a way as to reflect what will then be EU law. Given the degree to which the European Union has already been able to shape the development of the Guidelines for Vitamin and Mineral Food Supplements to match its highly restrictive EU Food Supplements Directive, the extent to which it will be able to do likewise with the Recommendations on the Scientific Basis of Health Claims should not therefore be underestimated.

In this respect it is particularly worth bearing in mind the now infamous statement of the European Commission delegate at the 2003 meeting of the Committee, that health claims for vitamin and mineral supplements should be prohibited. Given that the Committee's Chairman, Dr. Rolf Grossklaus, stated at the same meeting that drugs are to mitigate and prevent diseases, and that the role of food supplements is to support the diet, the type of world that both the European Union and Codex envisage is now becoming increasingly apparent.

Discussion Paper on Risk Analysis

This discussion paper was prepared by a working group coordinated by Australia. The eventual outcome of this work has enormous relevance to the future development of the Guidelines for Vitamin and Mineral Food Supplements, as the Guidelines state that the upper safe levels of vitamins and minerals in supplements will be established by scientific risk assessment.

Notably therefore, when this agenda item was discussed at last year's meeting the Committee indicated that it would be dealing with the "over dosage of nutrients." The content of this year's discussion paper continues in much the same vein, making it abundantly clear that the Committee is intending to treat vitamins and minerals as dangerous chemicals, as opposed to essential dietary elements. Until such time as this approach changes, therefore, our health and freedoms will continue to be at risk.

The good news however is that due to a shortage of time there was very little discussion on this agenda item this year. Ominously, however, the Committee's Chairman, Dr. Rolf Grossklaus, stated that this work was of enormous importance, and that it should be given the highest priority. As such it appears likely that substantially more discussion time will be given over to this issue at next year's meeting of the Committee, in Thailand.

In addition however, it was also announced during the meeting that the final report from the FAO/WHO Nutrient Risk Assessment Project is currently being prepared, and that this should be available during or before early 2006. Moreover, the report will then be discussed at next year's meeting of the Committee. As such it seems likely that FAO/WHO will now be very influential upon not only the development of the NRVs, but also the setting of the upper safe levels for the Guidelines for Vitamin and Mineral Food Supplements.

The FAO/WHO Nutrient Risk Assessment Project has thus far been conducted with a disturbing lack of transparency and accountability, and, as such, the fears of many observers - that the project could eventually result in maximum levels being set for vitamin and mineral supplements that are little better than, and in some cases identical to, the RDAs - would currently appear to be entirely justified.

WHO Global Strategy on Diet, Physical Activity and Health

The WHO Global Strategy on Diet, Physical Activity and Health was endorsed by the World Health Assembly in May 2004, and recognizes that a few largely preventable risk factors account for most of the world's disease burden. Describing how cardiovascular disease, diabetes, cancers and obesity-related conditions now account for some 60% of global deaths and almost half (47%) of the global burden of disease, the Strategy explains how healthier diet, nutrition and physical activity can help to prevent and control these illnesses.

At the July 2005 meeting of the Codex Alimentarius Commission, in Rome, it was decided that the potential areas for action by Codex in relation to the implementation of the Global Strategy were mainly relevant to the work of the Codex Committee on Food Labelling (CCFL) and the CCNFSDU; and that WHO, in cooperation with FAO, would produce a document for consideration by these committees, including specific proposals for new work.

Discussions on this agenda item had originally been scheduled to take place very early on in this year's CCNFSDU meeting, under agenda item 2. However, the Committee decided instead to move this debate to the very end of the last day of its meeting, and as a result there was only a very limited amount of time available to discuss the matter.

During the short discussion that did take place WHO presented a new two-page proposal document for the Committee's consideration. Unfortunately, however, the vast majority of delegations had not even seen the document because its presence had not been previously announced and the WHO had apparently run out of copies to distribute. After a short debate therefore the Codex Secretariat stated that the Committee should report to the Codex Alimentarius Commission that there had been insufficient time to fully address the proposal, and it was decided that Codex delegations could submit comments upon the proposal to FAO/WHO by email. Nevertheless, it seemed clear that the lack of proper discussion time for this issue was totally intentional, rather than merely accidental.

Conclusion

As can be seen, the work of the CCNFSDU remains a significant danger to the future of natural healthcare and health freedom.

Specifically, the pro-pharmaceutical lobby want to see the NRVs to be set at, or near to, RDA levels, thus weakening the arguments in favour of dietary supplements; the Recommendations on the Scientific Basis of Health Claims to as far as possible prevent the communication of lifesaving information by dietary supplement manufacturers; the Discussion Paper on Risk Analysis to be developed in such a way as to ensure that the upper safe levels of vitamins and minerals are set as low as possible; and the implementation of the WHO Global Strategy on Diet, Physical Activity and Health to be delayed for as long as possible and to not interfere with the multi-trillion dollar 'business with disease'.

Clearly, therefore, now more than ever we must remain vigilant, as the most potentially damaging aspects of the CCNFSDU's attacks on natural healthcare and health freedom are still to come.