Andrew Saul Speaks Before the Parliament of Canada

Vitamin Toxicity


TESTIMONY by Andrew W. Saul before the Government of Canada, House of Commons Standing Committee on Health, regarding natural health product safety (Ottawa, May 12, 2005).



by Andrew W. Saul


(Andrew W. Saul has taught clinical nutrition for New York Chiropractic College, and taught health science and biology for the State University of New York for nine years. The author of three nutrition books, Saul is also Contributing Editor for the Toronto-based Journal of Orthomolecular Medicine.)




Natural health products, such as amino acids, herbs, vitamins and other nutritional supplements, have an extraordinarily safe usage history. In the USA, close to half of the population takes herbal or nutritional supplements every day. That is over 145,000,000 individual doses daily, for a total of over 53 billion doses annually.


The most elementary of forensic arguments is, where are the bodies?


To try to answer this question, we may turn to the 2003 Annual Report of the American Association of Poison Control Centers Toxic Exposures Surveillance System, published in the American Journal of Emergency Medicine, Vol. 22, No. 5, September 2004. (http://www.aapcc.org/Annual%20Reports/03report/Annual%20Report%202003.pdf)


This report states that there have been four deaths attributed to vitamin/mineral supplements in the year 2003. Two of those deaths were due to iron poisoning. That means there have been two deaths allegedly caused by vitamins, out of over 53 billion doses. That is a product safety record without equal.


Pharmaceutical drugs, on the other hand, caused over 2,000 poison control-reported deaths, including


Antibiotics: 13 deaths

Antidepressants: 274 deaths

Antihistamines: 64 deaths

Cardiovascular drugs: 162 deaths


It would be incorrect to state that only prescription drugs kill people. In 2003, there were 59 deaths from aspirin alone. That is a death rate nearly thirty times higher than that of iron supplements. Furthermore, there were still more deaths from aspirin in combination with other products.


Fatalities are by no means limited to drug products. In the USA in the year 2003, there was a death from "Cream/lotion/makeup," a death from "Granular laundry detergent," one death from "Gun bluing," one death from plain soap, one death from baking soda, and one death from table salt.


Other deaths reported by the American Association of Poison Control Centers included:


aerosol air fresheners: 2 deaths

nailpolish remover: 2 deaths

perfume/cologne/aftershave: 2 deaths

charcoal: 3 deaths

dishwashing detergent: 3 deaths

(and interestingly, weapons of mass destruction: 0 deaths)


In America in 2003, there were 28 deaths from heroin, and yet acetaminophen ("Tylenol") alone killed 147. Though acetaminophen killed over five times as many, few would say that we should make this generally-regarded-as-safe, over-the-counter pain reliever require prescription. Even caffeine killed two people in 2003, a number equal to the two fatalities attributed to non-iron vitamin/mineral supplements. Tea, coffee and cola soft drinks are not sold with restriction, prescription, or in childproof bottles, and rather few would maintain that they need to be.




Nutritional supplements are exceptionally safe. In 2003, there were no deaths from multiple vitamins without iron. There were no deaths from amino acids. There were no deaths from B-complex vitamin supplements. There were no deaths from niacin. There were no deaths from vitamin A. There were no deaths from vitamin D. There were no deaths from vitamin E.


There was, supposedly, one alleged death from C and one alleged death from B-6.

The accuracy of such attribution is questionable, as water-soluble vitamins such as B-6 (pyridoxine) and vitamin C (ascorbate) have excellent safety records stretching back for many decades. "Vitamin problem" allegations are routinely overstated and unconfirmed. The latest (2003) Toxic Exposures Surveillance System report indicates that reported deaths are "probably or undoubtedly related to the exposure," a clear admission of uncertainty in the reporting. (p 340)


Even if true, such events are aberrations. For example, In 1998, the American Association of Poison Control Centers' Toxic Exposure Surveillance System reported no fatalities from either vitamin C or from B-6. In fact, that year there were no vitamin fatalities whatsoever. For decades I have asked my readers, colleagues, and students to provide me with any and all scientific evidence of a confirmed death from either of these two vitamins, or from any other vitamin. I have seen none to date.


Even the mistakenly-believed "side effects" of vitamin C have been found to be completely mythical. According to a National Institutes of Health report published in the Journal of the American Medical Association (April 21, 1999), none of the following problems are caused by taking "too much vitamin C":


Allegations of Hypoglycemia

Allegations of Rebound scurvy

Allegations of Infertility

Allegations of Destruction of vitamin B-12


Rather than focus on infinitesimally minimal supplement risk, it is vitamin deficiency that is the vastly more serious public health issue. For example, B-6 (pyridoxine) supplementation should be actively encouraged, as larger-than-food quantities of this vitamin has been demonstrated to prevent both cardiovascular disease and depression, diseases that are enormous public health problems. Women who use the birth control pill experience vitamin B-6 deficiency, and need to be encouraged to supplement with it. (Wynn, V. Lancet, March 8, 1975.)




Vitamin A, as carotene or fish oil, gives you healthy mucus membranes, a strong immune system, and helps prevent cancer.


In one review of 50 years of vitamin research, researchers noted that "approximately 10 to 15 cases of vitamin A toxic reactions are reported per year in the United States, usually at doses greater than 100,000 IU. No adverse effects have been reported for beta-carotene (a vitamin A precursor)." (Meyers DG, Maloley PA, Weeks D. Safety of antioxidant vitamins. Arch Intern Med. 1996 May 13;156(9):925-35.)


After first taking note that this review confirms safety, some explanation is necessary. First, a "toxic reaction" is very different from a "fatality." Had their been any fatalities, the authors would have said as much. Unfortunately, "toxic" may erroneously imply "deadly." That is not the meaning of toxic as it properly applies here: toxic means "makes you sick." American poison control statistics repeatedly fail to show even one single death from vitamin A in a given year.


Pregnancy is a special case where prolonged intake of too much preformed oil-form vitamin A might be harmful to the fetus, even at relatively low levels (under 25,000 IU/day). Interestingly enough, you can get over 100,000 IU of vitamin A from eating only six ounces of beef liver. I have yet to see a pregnancy overdose warning on a package of liver.


It is vitamin A deficiency during pregnancy, and in infancy, that poses the far greater risk. Deficiency of vitamin A in developing babies is known to cause birth defects, poor tooth enamel, a weakened immune system, and over 100,000 cases of blindness annually. Megadoses of vitamin A are considered sufficiently safe to be given to newborns to prevent infant deaths and disease. (Basu S, Sengupta B, Paladhi PK.Single megadose vitamin A supplementation of Indian mothers and morbidity in breastfed young infants. Postgrad Med J. 2003 Jul;79(933):397-402. And: Rahmathullah L, Tielsch JM, Thulasiraj RD, Katz J, Coles C, Devi S, John R, Prakash K, Sadanand AV, Edwin N, Kamaraj C. Impact of supplementing newborn infants with vitamin A on early infant mortality: community based randomized trial in southern India. BMJ. 2003 Aug 2;327(7409):254.)




The safety record of the B-complex vitamins is extraordinarily good. Since their discovery, beginning with thiamin (B-1) in 1911, many thousands of studies have verified an unequaled therapeutic value of these essential substances. Side effects have been rare, and toxicity is nearly nonexistent, even at the highest doses.


B-1, B-2, B-12, Biotin, Folate, Pantothenic Acid


Regulating blood sugar, nourishing your nerves, improving mood, and preventing cardiovascular disease are just a few reasons people take the B-complex vitamins. They are cheap and safe. Both the 1998 and 2003 American Association of Poison Control Centers' Toxic Exposure Surveillance System report shows no deaths whatsoever from Thiamin (B-1), Riboflavin (B-2), Cobalamin (B-12), Biotin, Folate or Pantothenic Acid. Furthermore, there are no toxicity reports published for these vitamins in the Merck Manual, generally regarded as a particularly authoritative medical reference.


Vitamin B-3 (Niacin; Niacinamide, Inositol Hexaniacinate)


For over 50 years, nutritional (orthomolecular) psychiatrists have used niacin (vitamin B-3) in doses as high as tens of thousands of milligrams per day. It is an effective treatment for obsessive compulsive disorder, anxiety, bipolar disorder, depression, psychotic behavior, and schizophrenia. Niacin has also gained popularity as one of the cheapest and safest ways to lower cholesterol.


The discoverer of niacin therapy for lowering cholesterol, Canadian psychiatrist Abram Hoffer, M.D., says that niacin is very safe. "There have been no deaths from niacin supplements," Dr. Hoffer says. "The LD 50 (the dosage that would kill half of those taking it) for dogs is 5,000-6,000 milligrams per kilogram body weight. That is equivalent to almost a pound of niacin per day for a human. No human takes 375,000 milligrams of niacin a day. They would be nauseous long before reaching a harmful dose. The top niacin dose ever was a 16-year-old schizophrenic girl who took 120 tablets (500 mg each) in one day. All that happened was that the 'voices' she was hearing stopped."


Physicians frequently give patients 2,0005,000 mg of niacin daily to lower cholesterol. The safety margin is very large. The 2003 American Association of Poison Control Centers' Toxic Exposure Surveillance System report indicates no deaths whatsoever from niacin.


Vitamin B-6


Vitamin B-6 (pyridoxine) improves mood, reduces risk of cardiovascular disease, and has been shown to be clinically effective against carpal tunnel syndrome. It also has been occasionally reported to cause temporary neurological symptoms such as heaviness, tingling, or numbness of the limbs in persons taking very large doses. It is very important to realize that such cases are not common, and when they do occur almost always result from huge doses of pyridoxine taken alone. B-6 by itself in doses of 2,000 to 6,000 mg daily (that is 1,200 to 3,600 times the standard U.S. dietary recommendation) can produce side effects. Very few persons report symptoms on 1,000 mg daily (600 times the US RDA), and only the rarest reports go any lower. When taken with, or as part of, a complete B-complex supplement, B-6 side effects are virtually unknown.


Premenstrual tension symptoms often improve dramatically with only a few hundred mg/day of extra B-6 taken in divided doses throughout the day. At least 50 to 100 mg of supplemental B-6 daily is a virtual necessity for women taking oral contraceptives. The "pill" causes some abnormal physiological changes that create a deficiency of B-6, as well as lower serum levels of thiamine (B-1), riboflavin (B-2), niacin (B-3), folic acid, B-12, and vitamin C.




The importance of vitamin C cannot be overemphasized. Vitamin C has been shown to be helpful in fighting over thirty major diseases, including pneumonia, herpes zoster (shingles), pancreatitis, hepatitis, arthritis, some forms of cancer, leukemia, atherosclerosis, high cholesterol, diabetes, multiple sclerosis, and chronic fatigue. (Vitamin C, Infectious Diseases, and Toxins: Curing the Incurable, by Thomas E. Levy, M.D. Philadelphia: Xlibris Corporation, 2002.)


Many well designed studies show that large doses of vitamin C improve both quality and length of life for cancer patients. (Murata, A., Morishige, F. and Yamaguchi, H. Prolongation of survival times of terminal cancer patients by administration of large doses of ascorbate. International Journal of Vitamin and Nutrition Research Suppl., 23, 1982, p. 103-113. And: Null, G., Robins, H., Tanenbaum, M., and Jennings, P. Vitamin C and the treatment of cancer: abstracts and commentary from the scientific literature. The Townsend Letter for Doctors and Patients. April/May, 1997. And: Riordan, N. H., et al. Intravenous ascorbate as a tumor cytotoxic chemotherapeutic agent. Medical Hypotheses, 44(3). p 207-213, March 1995.)


"Vitamin C," wrote board-certified chest physician Frederick R. Klenner, M.D., "is one of the safest substances you can put in the human body." Vitamin C is remarkably safe even in enormously high doses. Compared to commonly used prescription drugs, side effects are virtually nonexistent. It does not cause kidney stones. In fact, vitamin C increases urine flow, favorably lowers urine pH, and prevents calcium from binding with urinary oxalate. All these features help keep stones from forming. (Gerster H. No contribution of ascorbic acid to renal calcium oxalate stones. Ann Nutr Metab. 1997;41(5):269-82. "In the large-scale Harvard Prospective Health Professional Follow-Up Study, those groups in the highest quintile of vitamin C intake (> 1,500 mg/day) had a lower risk of kidney stones than the groups in the lowest quintiles.")


It was Canadian physician William J. McCormick, M.D., who first advocated vitamin C to prevent and cure the formation of kidney stones 50 years ago (McCormick, WJ. Lithogenesis and hypovitaminosis. Medical Record. 159:7, July, p 410-413). In 1946 he wrote:


"I have observed that a cloudy urine, heavy with phosphates and epithelium, is generally associated with a low vitamin C status. . . and that as soon as corrective administration of the vitamin effects a normal ascorbic acid (vitamin C) level the crystalline and organic sediment disappears like magic from the urine. I have found that this change can usually be brought about in a matter of hours by large doses of the vitamin, 500 to 2,000 mg, oral or parenteral." (p. 411) [Journal of Orthomolecular Medicine, Vol. 18, No. 2, 2003, p 93-96.]


Even a modest quantity of supplemental vitamin C prevents disease and saves lives. Just 500 mg daily results in a 42 percent lower risk of death from heart disease and a 35 percent lower risk of death from any cause. (Enstrom J.E., Kanim L.E., and Klein M.A. Vitamin C intake and mortality among a sample of the United States population. Epidemiology 3 (1992):194202.) Since at least two-thirds of the population is not eating sufficient fruits and vegetables, the only way to close the gap is with vitamin supplements.




Canadian researcher Reinhold Vieth, Ph.D., writes, "Published cases of vitamin D toxicity with hypercalcemia, for which the 25(OH)D concentration and vitamin D dose are known, all involve intake of greater than or equal to 1,000 micrograms (40,000 IU)/day. (T)he weight of evidence shows that the currently accepted, no observed adverse effect limit of 50 microg (2,000 IU)/d is too low by at least 5-fold." (Vieth R. Vitamin D supplementation, 25-hydroxyvitamin D concentrations, and safety. Am J Clin Nutr. May; 69(5):842-56. 1999.)


The Nutrition Desk Reference, Second Edition states that, for vitamin D, "The threshold for toxicity is 500 to 600 micrograms per kilogram body weight per day." (p 40) The US Environmental Protection Agency's published oral LD50 for female rats of 619 mg/kg (Cholecalciferol (Vitamin D3) Chemical Profile 12/84. US Environmental Protection Agency, Washington, DC. Chemical Fact Sheet Number 42. December 1, 1984.)


500 to 600 mcg is the equivalent of 20,000 to 24,000 IU, per kilogram body weight per day. By comparison, this would mean that for an average (70 kg) adult human, toxicity would occur at an astounding 1,400,000 to 1,680,000 IU/day.


Yet misconceptions and misinformation about vitamins persist. Vitamin-scare articles are unduly popular with the media, sometimes even making it into the pages of the Wall Street Journal. On April 30, 1992, David Stipp reported that between 1990 and 1992, "a series of patients with vitamin D overdoses began turning up at Boston hospitals." Due to problems at one large dairy, some of the milk sold in Boston contained over 230,000 units of vitamin D per quart instead of the usual 400 units per quart.


One person subsequently died from drug complications, and the case went to court. (Tarpey v. Crescent Ridge Dairy, Inc., 47 Mass. App. Ct. 380.) "Essentially, this was a product liability action against the producer of dairy products, specifically milk which contained excessive amounts of Vitamin D. The plaintiff's decedent purportedly suffered from elevated levels of Vitamin D in her bloodstream which required medication which in turn allegedly compromised her immune system, leading to her death." (http://www.dwpm.com/content/main/litigation00_news.php3)

This is the one and the only vitamin D-related death I could find confirmation of, ever, anywhere. And even this one was not directly due to the vitamin, but rather to side effects of medication.


The incident might well be taken as an unintentional proof of vitamin safety, even in ridiculously high overdosage situations. It is certainly noteworthy that 580 times the normal amount of vitamin D produced, at most, one alleged fatality. This borders on the extraordinary. Events such as this demonstrate that the margin for error with vitamins is very large indeed.


As a former university nutrition instructor, the classroom textbooks I taught with considered vitamin D to be perhaps the most potentially dangerous vitamin to chronically overdose on. If that is true, and there has been not even one confirmed vitamin-D fatality in the USA in over forty years, then all other vitamins are safer still. (Journal of Orthomolecular Medicine, 2003; Vol. 18, Numbers 3 and 4, p. 194-204.)




Poison control statistics report no deaths from vitamin E. Vitamin E is a safe and remarkably non-toxic substance. Canadian cardiologists Drs. Wilfrid and Evan Shute observed no evidence of harm with doses as high as 8,000 IU/day. In fact, "toxicity symptoms have not been reported even at intakes of 800 IU per kilogram of body weight daily for 5 months," according to the US Food and Nutrition Board. This demonstrated safe level would work out to be around 60,000 IU daily for an average adult, some 2,700 times the US RDA.


A Columbia University study reported progression of Alzheimer's disease was significantly slowed in patients taking high daily doses (2,000 IU) of vitamin E for two years. The vitamin worked better than the drug selegiline did. The patients in the Alzheimer's study tolerated their vitamin E doses well. Perhaps the real story is that 2,000 IU per day for two years is safe for the elderly.


Overexposure to oxygen has been a major cause of retrolental fibroplasia (retinopathy of prematurity) and subsequent blindness in premature infants. Incubator oxygen retina damage is now prevented by giving preemies 100 mg E per kilogram body weight. That dose is equivalent to an adult dose of about 7,000 IU for an average-weight adult. "There have been no detrimental side effects" from such treatment, said the New England Journal of Medicine. (Hittner HM, Godio LB, Rudolph AJ, Adams JM, Garcia-Prats JA, Friedman Z, Kautz JA, Monaco WA. Retrolental fibroplasia: efficacy of vitamin E in a double-blind clinical study of preterm infants. N Engl J Med. 1981 Dec 3; 305(23):1365-71.)


Regular supplementation with vitamin E is likely to save literally millions of lives. The New England Journal of Medicine published two papers in the May 20, 1993 issue showing that persons taking vitamin E supplements had an approximately 40% reduction in cardiovascular disease. Nearly 40,000 men and 87,000 women took part in the studies. The more vitamin E they took, and the longer they took it, the less cardiovascular disease they experienced.


A 1996 double-blind, placebo-controlled study of 2,002 patients with clogged arteries demonstrated a 77% decreased risk of heart attack in those taking 400 to 800 IU of vitamin E. (Stephens, NG et al. Randomized controlled trial of vitamin E in patients with coronary artery disease: Cambridge Heart Antioxidant Study (CHAOS)," Lancet, March 23, 1996; 347:781-786.)


Such effective quantities of vitamin E positively cannot be obtained from diet alone. 800 IU is 2,667% of the US DRI for vitamin E. (Journal of Orthomolecular Medicine, Volume 17, Number 3, Third Quarter, 2002 (p 179-181) And: Journal of Orthomolecular Medicine, 2003; Vol. 18, Numbers 3 and 4, p. 205-212.)




The 2003 Report of the American Association of Poison Control Centers Toxic Exposures Surveillance System (http://www.aapcc.org/Annual%20Reports/03report/Annual%20Report%202003.pdf)

indicates a total of 13 deaths attributed to herbal preparations. Three of these are from ephedra, two from yohimbe, and two from ma-huang. I have worked extensively in the alternative health field for nearly 30 years, and I have known of virtually no one who has taken ephedra, yohimbe, or ma-huang, and certainly not in the deliberately abusive high quantities that it takes to kill someone. Nevertheless, accepting all seven deaths attributed to these products, we still find that there were 30 times as many deaths from aspirin and acetaminophen.


Only three deaths are attributable to other "single ingredient botanicals," and oddly enough, their identity remains unnamed in the Toxic Exposures report.


Millions of persons take herbal remedies, and have done so for generations. Indigenous and Westernized peoples alike have found them to be safe and effective, and the 2003 Report of the American Association of Poison Control Centers Toxic Exposures Surveillance System confirms this (p 388-389). There have been no deaths at all from "cultural medicines," including ayurvedic, Asian, Hispanic, and in fact, from all others.


Additionally, we find:


Blue cohosh: 0 deaths

Ginko biloba: 0 deaths

Echinacea: 0 deaths

Ginseng: 0 deaths

Kava kava: 0 deaths

St John's wort: 0 deaths

Valerian: 0 deaths


Furthermore, there have been no deaths from phytoestrogens, glandulars, blue-green algae, or homeopathic remedies.




Of the eight deaths in the category, five of them are from non-supplement sources rightly termed "electrolytes": two from sodium and three from potassium (p 389). Two deaths were allegedly due to iron overdose. Since 1986, there has been an average of two deaths per year "associated with" iron supplements. The sole remaining death was from calcium, a mineral that is employed medically for its antidote properties. In fact, in 2003, calcium was used as a lifesaving antidote in 5,228 cases (p 344). There is no evidence that the single listed calcium death was from a supplement, and the odds are overwhelming that it was not.




In 2003, poison control centers reported no deaths whatsoever from amino acids. This is in itself a strong safety statement.




Supplementation's harshest critics have traditionally railed against vitamins (especially in large doses) as being outright "dangerous" and at the very least "a waste of money." Yet nutritional supplements are very safe, and for much of the population, very necessary. The Journal of the American Medical Association has recently published the recommendation that every person take a multivitamin daily (Fletcher RH and Fairfield KM. Vitamins for Chronic Disease Prevention in Adults: Clinical Applications JAMA. 2002; 287:3127-3129. And: Fairfield KM and Fletcher RH. Vitamins for Chronic Disease Prevention in Adults: Scientific Review. JAMA. 2002; 287:3116-3126.) saying that "(S)uboptimal intake of some vitamins, above levels causing classic vitamin deficiency, is a risk factor for chronic diseases and common in the general population, especially the elderly." Therefore, JAMA's intent goes beyond routine nutritional insurance for widespread bad-to-borderline diets. The goal is stated in the article's title: "Vitamins for chronic disease prevention in adults." It is a sensible idea whose time should have come generations ago.


To illustrate how extraordinarily important supplements are to persons with a questionable diet, consider this: Children who eat hot dogs once a week double their risk of a brain tumor. Kids eating more than twelve hot dogs a month (that's barely three hot dogs a week) have nearly ten times the risk of leukemia as children who ate none. (Peters JM, Preston-Martin S, London SJ, Bowman JD, Buckley JD, Thomas DC. Processed meats and risk of childhood leukemia. Cancer Causes Control. 1994 Mar; 5(2):195-202.)


However, hot-dog eating children taking supplemental vitamins were shown to have a reduced risk of cancer. (Sarasua S, Savitz DA. Cured and broiled meat consumption in relation to childhood cancer. Cancer Causes Control. 1994 Mar; 5(2):141-8.)


It is curious that, while theorizing many "potential" dangers of vitamins, the media often choose to ignore the very real cancer-prevention benefits of supplementation.


Critics also fail to point out how economical supplements are. For low-income households, taking a two-cent vitamin C tablet and a five-cent multivitamin, readily obtainable from any discount store, is vastly cheaper than getting those vitamins by eating right. The uncomfortable truth is that it is often less expensive to supplement than to buy nutritious food, especially out-of-season fresh produce.


According to David DeRose, M.D., M.P.H., "300,000 Americans die annually from poor nutrition choices." Supplements make any dietary lifestyle, whether good or bad, significantly better. Supplements are an easy, practical entry-level better-nutrition solution for the public. A television-educated populace is more likely to take some tablets than to willingly eat organ meats, wheat germ, bean sprouts and ample vegetables. Media supplement-scare-stories notwithstanding, taking supplements is not the problem; it is a solution. Malnutrition is the problem. (Journal of Orthomolecular Medicine, 2003; Vol. 18, Numbers 3 and 4, p. 213-216.)




A recent (March 26, 2003) and unsuccessful American attempt to restrict free public access to vitamin supplements was U.S. Senate Bill S. 722, the so-called "Dietary Supplement Safety Act of 2003." The proposed law attempted to give the Secretary of the US Food and Drug Administration sole power decide if and when "the continued marketing of the dietary supplement is disapproved" (2-B: ii) based on adverse event reporting so vague that the proposed bill specified that decision was "without regard to whether the event is known to be causally related to the dietary supplement." (SEC. 416 (a)(1)


The intent of S. 722 was to overturn the main provisions of the U.S. Dietary Supplement Health and Education Act of 1994 (DSHEA). The US Congress enacted DSHEA specifically to define vitamins, amino acids, herbs, and other nutritional supplements as foods, not drugs. DSHEA enjoyed tremendous popular support. More citizen letters were sent to Congress in 1992-1994 in favor of DSHEA than over any other issue in American history. Some 2.5 million individual voters' letters were received by US Senators and Representatives. On the other hand, citizen opposition to S. 722 was strong. It gathered only four cosponsors, and failed in committee.


The U.S. Congress has clearly seen that there is overwhelming public support for ensuring free access to dietary supplements. I believe Canadians have the same keen interest, and that an affirmative vote on Canada's proposed legislation, C-420, to rightly consider supplements as foods and not drugs, will be well-received by the citizens of Canada.




As it has been for thousands of years of human history, so the malnutrition problem remains with us today. Only in the last century have supplements even been available. Their continued use represents a true public health breakthrough on a par with clean drinking water and sanitary sewers, and can be expected to save as many lives.


The number one side effect of vitamins is failure to take enough of them. Vitamins are extraordinarily safe substances. Drugs are not. There are over 106,000 deaths from pharmaceutical drugs each year in the USA, even when prescribed correctly and taken as prescribed. (Lucian Leape, Error in medicine. Journal of the American Medical Association, 1994, 272:23, p 1851. Also: Leape LL. Institute of Medicine medical error figures are not exaggerated. JAMA. 2000 Jul 5;284(1):95-7.)


Public supplementation should be encouraged, not discouraged. Supplements are a cost-effective means of preventing and ameliorating illness. Supplement safety is outstandingly high. Natural health products should be classified as foods, not drugs.


(end of testimony)


Andrew Saul is the author of the books FIRE YOUR DOCTOR! How to be Independently Healthy (reader reviews at http://www.doctoryourself.com/review.html ) and DOCTOR YOURSELF: Natural Healing that Works. (reviewed at http://www.doctoryourself.com/saulbooks.html )



"A lot of people go through life trying to prove that the things that are good for them are wrong." (Ward Cleaver, on "Leave it to Beaver")


"There is a principle which is a bar against all information, which is proof against all argument, and which cannot fail to keep man in everlasting ignorance. That principle is condemnation without investigation." (Herbert Spencer)



Andrew W. Saul


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