From: Harvey Newstrom (mail@HarveyNewstrom.com)
Date: Fri Jun 29 2001 - 08:57:03 MDT
Robert J. Bradbury wrote,
> I am going to stand corrected (read as: "I was probably WRONG
> on some, perhaps many counts") because Harvey seems to be
> presenting reputational evidence that he has researched
> this in greater detail than my simple exposure to the literature
> over the last 10 years. So while I'm an "well-informed" source, he
> probably weighs in as an "expert witness" on the details of the
> current labeling laws (which of course vary significantly from
> country to country).
>
> I will simply make a n.b. that if he had explained that at
> the beginning we might have saved some time...
Thanks for this kind concession. I don't like to whip out credentials to
see whose is larger, because it usually doesn't add anything to the
conversation.
Also note that we are discussing what we "should" do. A lot of this is
personal desire or design parameters. There may not be a "right" or "wrong"
position. I admit that my labeling desire are probably unusual and quite in
the minority. I want full labeling, but I don't want the government to
enforce it. I want companies to voluntarily comply, but I don't trust them
to be honest. I want informed consumer, but I lack faith that most will
understand what they read. As such, I actually have a lot conflicting and
contradictory thoughts on this subject. I value all the positions and
insights that opposing viewpoints can generate.
> So I will grant that Harvey is probably the expert on
> precisely what the labels must state or may not state.
>
> I think our differences of opinion may be wrapped up in
> the detailed definition of what the FDA classifies as
> an "ingredient" and a "contaminant". This is different
> from the rules regarding occupational exposure which
> I'm under the impression are dealt with by OSHA and/or
> the EPA.
This is a very good point, because it is not clear whether a genetically
expressed chemical is a food additive or an innate ingredient. It is "new",
yet "natural", yet "engineered", yet "default", yet "different". We will
probably find that current laws can't handle the changing technology, and we
are using complicated arguments to fit square pegs into round holes.
> Further comments:
> If they are classifying B.C. as Vitamin A, then I'd like to see
> the rationale behind it because this is dangerous to the consumer.
> You could consume a huge amount of B.C. with no increase in risk,
> while consuming an equivalent amount of Vitamin A could be dangerous.
> Hiding B.C. as a Vitamin A equivalent would seem to be placing the
> consumer at risk.
These are laws. They don't have to have rationale. :-)
Actually, vitamin A is reported in "international units" of vitamin A, which
is defined as 0.2 micrograms of retinol (vitamin A1) or 1.2 micrograms of
beta-carotene (pro-vitamin A). They also allow vitamin A2, vitamin A
acetate, vitamin A acid, vitamin A aldehyde, vitamin A epoxide, vitamin A
palmitate, monoepoxy-vitamin A and Neovitamin A to be counted as vitamin A.
The "international units" measures "vitamin A activity" such that the body
gets the same amount of value out of different chemicals used for vitamin A.
You indeed point out some good examples why it might be dangerous to label
all these different things with the same label. The food manufacturers
fought against labeling the different forms of vitamin A, fearing that
customers might value one form over another. They argued that all these
forms are functionally equivalent. As you pointed out, vitamin A (retinol)
can be quite toxic, while beta-carotene is nontoxic. Also, diabetics have
trouble using beta-carotene as vitamin A, so they need to get more direct
retinol forms.
Most vitamins are defined as "biological activity", and any substance that
fills that need can be counted as a different form of that vitamin. Thus,
we end up with dozens of different chemicals that are called the same thing
on ingredient lists. Sometimes there are major differences. Nicotinic acid
(vitamin B3a) lowers cholesterol whereas nicotinamide (vitamin B3b) does
not. Both substances are called "vitamin B3" or "niacin" on food labels.
You cannot tell which one you are getting.
>
> > This has nothing to do with my point. Rice does not contain
> beta-carotene. Golden rice does.
>
> Yes, but according to the "greens" also in small amounts insufficient
> to impact human health (I haven't verified this).
I haven't heard this. Without knowing the facts, I would guess that any
amount of beta-carotene that is abundant enough to color the rice would have
to be abundant enough to add nutritional value. This would especially be
true where rice was a major staple in the diet. (Again, I am guessing
here.) On the other hand, beta-carotene is a fat-soluble vitamin that
requires fat to convert it into two vitamin A molecules. Eating just rice
would not provide the fat required to utilize this form of vitamin A. If a
poor diet contained no meat and no milk, and no soy oils, it might be hard
to absorb betacarotene from rice. I will have to research this further! It
may be that golden rice by itself can't provide vitamin A value, and that a
diverse diet in addition to the rice would still be needed.
> [I'll note as an aside
> there are still extensive debates in the literature regarding
> the medical/health significance of the various benefits (or "harms")
> of the "natural" vs. "synthetic" forms of Vitamin E and perhaps
> B.C.]
Basically, "natural" vitamin E contains a mixture of alpha, beta, gamma,
delta, epsilon-1 and epsilon-2 tocopherols. "Synthetic" vitamin E is
standardized to alpha tocopherol. "Natural" vitamin E contains only the L-
form of tocopherol which is the "left-handed" molecule. The synthetic
manufacture process produces equal amounts of L- and D- molecules, which are
the "left-handed" and "right-handed" mirror images of the vitamin. It is
not established that the body needs all forms of vitamin E, but it will use
them all if present. It also is not established that it is bad to have
extra mirror images of the vitamin in the mixture.
The confusing part is that the "natural" vitamin E is not the same as the
"synthetic" vitamin E. Therefore, there could be differences. We *can*
manufacture exact duplicates of the natural chemicals, but this costs more.
There is a strong debate, but I'm not sure there are proven health
differences between the different forms. There are some hints of possible
differences, but the body usually can convert between the forms to get what
it needs.
> > This seems to be dumbing down information to the lowest common
> denominator.
>
> Yep, sad but true. People want (and presumably need) "distilled"
> information.
Just as the news media distills down information to the key points, it is a
lossy compression. It is probably good enough for most people, but some
will complain that the compression changes the content and affects the
overall subject matter. I am in this latter category, but agree I am in the
minority. Most people can't hear or see the losses in digital media, but it
annoys me. Most people can't see color differences between daylight and
fluorescent tubes, but I find everything indoors to be colored purplish.
Maybe the differences aren't enough to effect most people. I agree that my
preference in these matters is probably beyond the noise level for most
people.
> > Just at a gut level, it seems to be anti-consumer, anti-market,
> > anti-knowledge and anti-choice. It might be the best public policy,
> > but it goes against my libertarian views for anarchy,
> self-determination,
> > and fully informed self governance. But that's just my opinion.
> > Obviously, most people disagree.
>
> I don't disagree, but I'm willing to be a humanitarian pragmatist.
> Most people currently do not have the luxury of having educated
> themselves about these topics to the degree that I or Harvey have.
> As a result they will "believe" whatever they are told by people
> with whom they have established a "trust" relationship without
> bothering to verify whether those individuals have a reputation
> worth paying attention to in the area under discussion.
I fear this is true. It is sad, but accurate. I myself can't be bothered
to research every subject that affects me. There are too many. I rely on
other people to tell me what to do much of the time. We can only become
experts in a select few areas. Therefore, I willingly concede that my
desired labeling requirements is probably unworkable or too complicated for
the general public.
-- Harvey Newstrom <http://HarveyNewstrom.com> <http://Newstaff.com>
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