Ridiculous Dietary Allowance An open challenge to the RDA for vitamin C by Dr Steve Hickey and Dr Hilary Roberts 1 All trademarks acknowledged. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying or otherwise without the prior permission of the copyright owner. Copyright © Dr Steve Hickey. All rights reserved. 2 Preface In recent years, there has been a controversy around Vitamin C’s contribution to health. Our aim in this book is to reveal the flaws in the research underlying the recommended daily allowance (RDA) for vitamin C, in the United States and United Kingdom. Various RDA values are purported to specify the minimum intake required for good health in different sections of the population, such as young children or the aged. For simplicity, we consider mainly the recommended intake for young adults. The RDA has been renamed Dietary Reference Value (DRV) in the UK since 1991. The UK government committees separated the RDA into several subsidiary values, claiming it had been used incorrectly to assess individual diets. The values are the estimated average requirement (EAR), reference nutrient intake (RNI), lower reference nutrient intake (LRNI) and safe intake (SI). A similar subdivision has occurred in the US RDA values, provided by the Institute of Medicine. The Food and Drug Administration had their own version of the RDAA for food labelling, based on the Institute of Medicine values; this term has now been changed to Dietary Reference Intake. The renaming and subdivision of RDA values is not pertinent to our discussion. We first came across the title, “Ridiculous Dietary Allowance”, as a description of the RDA by Dr Ron Hunninghake. We thought the phrase was apt, so we borrowed it for our title. There are many derivatives, such as “Ridiculous Dietary Arbitrary”. The common use of these slightly derogatory phrases by nutritional scientists indicates the disdain they feel for the RDA concept and its official implementation. Most of the references are to the recommendations of the Food and Nutrition Board of the US Institute of Medicine. We describe the Food and Nutrition Board as “the committee” throughout. The book also covers the information provided as justification for the upper limits on intake by the Expert Group on Vitamins and Minerals (EVM) of the Food Standards Agency in the UK.1,2,3,4 We generally refer to the EVM as the UK committee, the expert committee or occasionally the committee. While the remit of the EVM was for determining the upper limit, much of their discussion relates to recommended intakes. This book covers the faulty science supporting Tolerable Upper Limits A The FDA RDA is sometimes called the U.S. RDA but we use the term US RDA to differentiate the US from the UK recommendations. 3 and the other nutritional measures associated with the RDA. The UK RDA in was actually determined in 1991 by the Committee of Medical Aspects of Food and Nutrition Policy (COMA),5 this committee has now been replaced by the Scientific Advisory Committee on Nutrition (SACN). Review of the dietary reference values for nutrients has been discussed by SACN but there is no timescale for actually carrying out this work.B,6 We therefore concentrate on the justification for the US RDA, as this essentially encompasses that of the UK recommendations and presents generally higher values. The recent work of the UK EVM on tolerable upper limits is included, as it links closely with the underpinnings of the Codex Alimentarius. While there are differences in the published accounts, the gross errors are consistent. The published justifications do not represent a cost benefit analysis and are selectively biased towards acceptance of low doses. The evidence used to support the US RDA is published elsewhere,7,8 and to avoid repetition we often refer to facts in these documents without specifically enumerating the reference. The justification for the RDA is essentially a review of a selected proportion of the available literature. We have often referred the RDA documents rather than the source papers, specifying the original papers where necessary. The references are provided as sources of additional information, as opposed to specific validation. We recommend readers who are interested in following the chain of evidence to examine the published RDA justifications, which are available online. This book follows the publication of “Ascorbate: The Science of Vitamin C”9 by the same authors. The Ascorbate book provides a synthesis of the current science on vitamin C and presents some new ideas, including the dynamic flow model. In the process, it brings into focus the ideas and experimental basis underlying the RDA. Since this account is supplementary to the Ascorbate book, the original references and full arguments are not presented here. Interested readers are encouraged to examine the background in more detail in the original book. In the present book, we assume that readers have a reasonable appreciation of the number of diseases vitamin C is claimed to prevent or treat, and the magnitude of the effect. Linus Pauling has described the potential health benefits of high doses of vitamin C, in his book “How to Live Longer and Feel Better”.10 Numerous other books and publications exist, but Pauling’s simple writing style and B A search of the SACN website found no results for “vitamin C”. 4 wonderful grasp of his subject make his books classics in this area. A reasonably full account of the pharmacology and medical uses of high doses of vitamin C has been provided by Dr Tom Levy, in his excellent book “Vitamin C, Infectious Diseases and Toxins”.11 We recommend this book to anyone interested in the use of high-dose ascorbate in treating disease. We have cited several papers by the NIH ascorbate pharmacokinetic group and associated researchers. In referencing these and related papers, we are explicitly not making a statement about the accuracy or validity of any part of this research. In the future, it may be necessary for us to illustrate further errors in these papers. The standard of the science used to support the RDA is, at best, suspect. In the text, we describe a simple qualitative cost-benefit analysis. We are aware that this approach generally applies to quantitative or quasi-quantitative methods. Our aim is simply to indicate that formal decision support theory12,13 would prevent the bias that is apparent in the current RDA and Tolerable Upper Limit recommendations. We have used the decision analysis terms in a loose way, consistent with a basic description. Our presentation has been simplified to draw attention to the arbitrary nature of the decision making process associated with the RDA for vitamin C and other nutrients. Describing the method in this qualitative way makes it easier to understand, while allowing a structured approach to the decision making process. The gross limitations in the methods employed in the RDA and upper limits for vitamin C are also found in the recommendations for other nutrients. In particular, we note that the current Codex Alimentarius proposals, based on Tolerable Upper Limits, lack scientific support and may result in innumerable cases of chronic disease and death. We have tried to be accurate in this book while simplifying the arguments for the non-specialist reader. This balance involves a compromise and readers should feel free to report any errors found in this text to [email protected]. 5 Acknowledgements We would like to thank Bill Sardi, for his magnificent efforts in publicising the challenge to the RDA. Bill is a medical journalist who claims to be a layman, although his knowledge of nutrition exceeds that of many specialists. Owen Fonorow of the Vitamin C Foundation was the original champion of the dynamic flow model. We greatly appreciate his work in making the claims for vitamin C known to the public. We would also like to thank the other experts who signed the letter requesting a re-evaluation of the RDA for ascorbate: Professor Ian Brighthope, Robert F. Cathcart III, MD, Abram Hoffer, MD, PhD, FRCP, Patrick Holford, Archie Kalokerinos, MD, Thomas Edward Levy, MD, JD, Richard A. Passwater, PhD, Hugh D. Riordan, MD, and Andrew W. Saul, PhD. Dr Balz Frei of the Linus Pauling Institute helped us by mounting a private defence of the RDA. His openness on the topic has been refreshing, when compared with the unscientific lack of communication from many establishment scientists. Dr David Lidbury, of the Institute of Optimum Nutrition, read the text for scientific content and provided many helpful comments. Dr Lidbury is currently working on a project with Patrick Holford on the rational evaluation of nutrient intakes. Optometrist Dr Sydney Bush provided helpful feedback and discussion of “CardioRetinometry”, a technique he proposes for the determination of scurvy. Dr Bush kindly provided information about his definition of scurvy in relation to retinal blood vessel damage and the sample images presented. Quentin Bush also helped and discovered retinal images showing changes in cholesterol. Dr Peter Keen provided feedback on the initial version of this book. Holly Matthies, Andrew Hickey, Pauline Rose and Gillian Perkins read the manuscript for errors and checked references. Billie Fonorow provided help with editing and checked parts of the manuscript for errors. 6 Dedicated to Bill Sardi, for his outstanding work in health and communication. 7 Introduction By Owen Fonorow, Co-founder, The Vitamin C Foundation In 1920 British biochemist Jack Cecil Drummond suggested that the antiscurvy factor in food, in the absence of chemical information as to the nature of the factor, be named "vitamin C." Other vitamins had been isolated and were found to be coenzymes, somewhat complicated substances that are required for life in small amounts in order to make the enzymes work properly. Nature, in its efficiency, provided these necessary substances in food because they would be difficult for human cells to manufacture; they occur in sufficient amounts in the ordinary diet. When these molecules are missing, a deficiency-disease results. Vitamin C was the exception to the vitamin rules almost from the beginning. Like the other vitamins, small amounts were observed to have powerful effects on those suffering from a deficiency-disease. Unlike other vitamins, which had few effects in healthy people taking more than an ordinary small amount of a vitamin, vitamin C was found to cure diseases other than scurvy when given in high amounts. The fragile substance was hard to isolate and was one of the last vitamins whose chemical nature was understood. Given the technical name ascorbic acid, it was found that vitamin C had a sugar- like molecular structure. Later, it was determined that ascorbic acid is not a vitamin necessary in the diet for the vast majority of animal species, most of which make large quantities in their kidneys or livers. In 1934, shortly after synthetic vitamin C became available, the medical world published the vitamin’s unexpected successes in disease-curing and prevention. Professor A. Szent-Gyorgyi, the Hungarian chemist who played a major role in the artificial manufacture of this vitamin, stated that “These curative effects suggest that humanity is suffering much more gravely from a lack of vitamin C than has hitherto been supposed.” Aware of these early findings regarding ascorbic acid, Linus Pauling wrote in 1986 that “Vitamin C has been under investigation, reported in thousands of scientific papers ever since it was discovered (circa) fifty years ago. Physicians had observed at that time that amounts of vitamin C of a hundred to a thousand times larger (than the RDA) have value in controlling various diseases.” 8 American biochemist Irwin Stone, the scientist who first brought the values of ascorbic acid in excess of the RDA to Linus Pauling’s attention in the late 1960s, had long argued that vitamin C had been misnamed a “vitamin”. Stone felt the name implied that the substance is only required in tiny amounts, and urged instead that it be called the "missing stress hormone" or simply ascorbate. Vitamin C may behave as a coenzyme in conditions that help control scurvy, but its molecular structure is unlike that of other (complicated) coenzymes. Vitamin C as ascorbic acid is derived from glucose in other plants and animals that manufacture it. Also, it shares with glucose many of the same mechanisms for entering and feeding of cells, including insulin- mediated transport into cells. Thanks to Linus Pauling, we know that super health can be attained by simply taking a few of certain pills daily, emphasizing ascorbic acid. Children are no exception. The following is a personal story that I believe demonstrates, first hand, the effectiveness of vitamin C when taken even before birth. In 1989, following the advice of American physician, Fred Klenner, MD, and after receiving the endorsement of Linus Pauling, my wife and I, before conception, provided our son with high amounts of vitamin C. She continued with 9,000 mg daily during pregnancy and more during lactation (10 grams). Our son has ingested multiple grams of ascorbic acid from early infancy, and continues to do so at age 14. He’s average height and lean, exceeds the performance of athletes in his physical fitness testing, and has had continuous unusually good health. He’s never had an ear infection that "every child" supposedly gets, and the only childhood illness he’s had was a mild case of chicken pox. There is no doubt in our minds that these positives in our son’s life, are, in great part, due to his taking Vitamin C. He supplements at least 6,000 mg of vitamin C daily, with added antioxidants vitamin A, E, B-complex and as complete a multiple vitamin/mineral as possible. This is the regimen described in Linus Pauling’s book, “How to Live Longer and Feel Better”. All parents deserve the joy of an optimally healthy child and it is easy. I have often made the statement to our son that although he has been ill, he has never really felt sick a day in his life. Once, when he questioned our assessment that he had never really felt ill, I asked him if he’d like to stop the vitamin C for a while and perhaps experience illness as others do. He declined. I now attribute feeling ill, generally, to the vitamin C depletion caused by fighting the disease. A similar effect causes the hangover after alcohol intake, which can be completely avoided by high dose vitamin C intake. 9 The Vitamin C Foundation recommends that everyone supplement 3000 mg ascorbic acid daily. With the knowledge of Dynamic Flow provided by Drs. Hickey and Roberts, we now suggest spacing that amount throughout the day, perhaps 1,000 mg with every meal. Note: this is our minimum daily allowance. Our recommendation is more that 30 times that of the U. S. Government’s National Academy of Sciences. (75-90mg) and 15 times more than that of the current Linus Pauling Institute and Levine’s group at the National Institutes of Health (200mg). Linus Pauling himself prescribed 2 to 6 times the Foundation’s vitamin C RDA (6,000 to 18,000 mg of vitamin C). Pauling wrote that his dosage was based on the large amounts of vitamin C that animals’ bodies manufacture to achieve similar levels. Vitamin C author/expert Thomas E. Levy, MD, JD, advises from 2 to 4 times our recommendation (6,000 to 12,000 mg daily). Our suggestions are based partly on the work of Dr. Robert Cathcart, who determined that the ability to tolerate oral intakes of the vitamin varies between 4 and 16 grams daily, during ordinary (not severe) poor health. Cathcart’s clinical experience demonstrates that almost all human beings will tolerate 4 grams of vitamin C daily. The Vitamin C Foundation advocates 1 gram vitamin C daily for children, based upon their age, up to the age of 3: 1 gram for 1- yr-olds; 2 grams for 2-yr olds, etc. Our suggested daily allowance may not prevent or resolve such diseases that are related to the lack of vitamin C. For example, we believe that heart disease requires from 6,000 to 18,000 mg Vitamin C daily, and that cancer may require 14,000 to 39,000 mg daily. The great unanswered question is why humans evolved differently than most animals. If vitamin C is more than a vitamin, how did the human species, like the guinea pig, fruit bat, and a number of higher level primates, survive after losing the ability to make ascorbic acid? Whatever the reason for our survival, there is little doubt this great deficiency in our genetic makeup, the lost ability to produce the enzyme L-gulonolactone oxidase in our livers, an enzyme that would otherwise allow us to convert ordinary glucose (sugar) into ascorbic acid, is what ultimately causes the major chronic illnesses of humankind. Oct 2004 10