Codex Working Group on Labeling of Pre-Packaged Foods
Ottawa, Ontario
Labeling of pre-packaged food may not sound very sexy, but it is of extreme importance to consumer decision making and to the economics of Big Agribiz/Big Food. Less food in the food being sold, more permissible deception, more fillers, additives and contaminants means more money for low integrity food producers. Consumers’ interests were not very well served today at the first of two Working Groups.
There is certain sameness to all of Codex meetings: they are all long, exceedingly detail oriented and, if you are not watching the political, economic and corporate scenery very, very closely, mind-numbingly dull. Time after time, while the minute details receive excruciating attention, examination and discussion, the provisions which could actually protect people, exclusively referred to as “consumers” on Planet Codex, are left for last, and, fascinatingly, time after time get taken up with [literally] seconds to go before the end of the meeting. Oops! No time to discuss them. Translators have to leave. SO sorry!
Today’s Working Group was an excellent example of this industry-friendly, consumer-unfriendly process. We started the day with a report for consideration on the Quantitative Ingredient Disclosure (QUID) labeling of pre-packaged foods. QUID labeling means that foods have to declare what percentage of what food they are made with so consumers have more information and more choice about what they buy.
Who is the leader in the Codex anti effective QUID movement? The US, of course. My observation was that the representatives of the US beverage, grocery manufacturers and frozen food industries appeared pretty happy with the way their helpful regulatory friend, the FDA, handled the whole thing. The FDA’s Dr. Barbara Schneeman was, is serving, as she so often does, as the US Delegate to this session.
The US has been quite strongly opposed to QUID but other countries, like the EU, Norway, Switzerland, are very fond of QUID labeling which helps consumers. If, for example, you want to buy salmon rolls stuffed with scallops you would find out from a QUID label that one brand contains 8% scallops in the stuffing while another brand contains 16% scallops. You could then decide whether the extra money for the second brand was worth it to you.
It is not hard to figure out that manufacturers do not want the responsibility, the expense or the revelation of how little real food they put into pre packaged foods.
There were two sections in the document (a draft amendment to another document) under discussion today which were, in fact, quite protective and helpful to consumers. When the one day workshop convened this morning to work on the draft amendment before sending it back to the full Codex Committee on Food Labeling for consideration next week the Chairman of the Working Group had prepared a proposed amended draft report for the Working Group to consider based on the submitted country and organization comments. In that document the two really helpful items were struck out without discussion or debate.
An NGO (Non Governmental Organization) called “IACFO” or International Association of Consumer Food Organizations, pointed out that the majority of comments from nations and organizations were positive about these two items and questioned why they were struck out of the report. The Chairman said that there would be plenty of time to discuss them. IACFO returned to this comment again and again. The Chair’s response was the same each time: there will be plenty of time for full discussion.
Well, I am sure you have guessed the end of the story. As the meeting was adjourning and the translators had to leave, there were about 2 minutes available for discussion of the two consumer-friendly items which the Chair had slated for elimination. No effective discussion was possible, obviously.
Same song, different verse. That is how it is done at Codex. Consumer-friendly items get short shrift but the “democratic fantasy” of full discussion and decision by consensus is maintained. The big win for consumers today was that the NGO succeeded in keeping the items alive so that they might, just might, get a full discussion in another forum, some other time.
One more thing about QUID: there was a rather ferocious debate in which the concept of having to indicate the amount of food in the name of the food was beaten down. For example, the amount of corn in corn flakes or rye in rye bread does not have to be “QUIDed”. Nor does the amount of sugar added. Nor does any food additive or contaminant require QUIDing. Nor the amount of radiation the food has received. What gets QUIDed in international trade will be those ingredients which give the food its special characteristic or commercial value. That does NOT include the foods that, to my mind, the consumer actually buys the food for and believes he/she is buying. Nor does it include the food or non food items (e.g., water, fillers, un-named ingredients) which manufacturers add without mentioning them.
In short, QUID, a potentially useful system to alert and inform consumers about their food stuffs, has been watered down by the resistance of the US and its friends to favor the commercial interests of the food industry, leaving the consumer literally in the dark. Norway, Ghana and a few other nations, along with IACFO did their best but the weight of the US was behind this outcome and so the results were predictable.
Tomorrow the Working Group will focus on Organic Standards. The Natural Solutions Foundation has prepared a formal submission on the topic which we have made available both to the United States Government in time for their pre-CCFL (Codex Committee on Food Labeling) meeting on April 10, 2007 and to various health friendly nations. You will find it in its entirety in the blog post called “Codex Organic Standards Comments by Natural Solutions Foundation”
Stay tuned for a day by day report on the CCFL meeting this week. We’re here for you!
And remember to spread the word on the urgent need to submit public comments during the extended comment period on the dangerous (but often soft-pedaled) FDA Guidance on CAM (which either means “Complementary and Alternative Medicine” or “Complementary and Alternative Modalities” – the difference is huge!) We’ve got 166,704 comments in already. If each person motivates 10 others, we will have enough to stem the tide of this dangerous attempt to eliminate all natural procedures, practices and products.
Yours in health and freedom,
Rima E. Laibow, MD
Medical Director
Natural Solutions Foundation
www.HealthFreedomUSA.org
Today, Saturday, April 28, 2007, the Working Group on the Proposed Draft Amendment for the Labeling of Prepackaged Food will meet in the Ottawa Congress Center, Ottawa, Canada. On Sunday, April 29, the Working Group for the Production, Processing, Labeling and Marketing of Organically Produced Foods will meet. Both meetings are a single day long each year. Both sort out thorny issues n dry as dust terms. But that dust, like the rest of Codex, contains the seeds of the future health of the planet within it. Each Working Group meets for a one day meeting held each year before the start of the Codex Committee on Food Labeling which is hosted by Canada in Ottawa annually.
After the meeting tomorrow I will fill you in on what takes place. What is going on at Codex is vitally important to your health and your planet. BUt what is going on at Codex is also going on at home, too.
Ralph Fucetola, a regulatory lawyer, has written a beautiful guest blog which follows. Please read it and pass it along to everyone in your circle of influence. It is a really important piece. By the way, Big Pharma’s agenda knows neither national borders nor compassion for the vulnerable. Senator Kennedy’s new bill shows neither sense nor respect for your rights. The FDA Guidance shows neither respect for your health nor your health freedom.
We, the people, are neither amused nor hoodwinked and are once again standing and roaring that we control our freedoms, we, not merchants and not politicians, and certainly not bureaucrats or doctors.
Here is Ralph’s Guest Blog:
A Natural Solutions Foundation Guest Editorial
www.vitaminlawyernews.com
FDA CAM DRAFT GUIDANCE INFORMATION
Docket No. 2006D-0480 – http://www.fda.gov/OHRMS/DOCKETS/98fr/E7-3259.htm
1. Guest Blog for NSF – 04/28/07
2. FDA CAM Threat Assessment – 04/26/07
3. Comments to FDA regarding CAM draft Guidance – 04/06/07
A Natural Solutions Foundation Guest Blog Entry
See: https://staging.drrimatruthreports.com/index.php/?p=367
Don’t be Duped: Multiple Assaults Need Multiple Responses
Our Health Freedom is threatened again. It’s been going on for centuries,
this struggle between healers and bureaucrats. Even back in the age of Henry
the 8th the surgeons of London got a law passed effectively outlawing their
herbalist competitors by granting themselves a monopoly, and, a couple years
later, after many herbalists were brought before the courts, the King had to
intervene, obtaining Parliamentary approval for what is now known in the
Common Law as The Herbalists Charter, to protect traditional methods of
healing and allow their practice “without suit, vexation, trouble, penalty
or loss…”1 As recently as the start of the Twentieth Century, one state
Supreme Court noted, “”The state has not restricted the cure of the body to
the practice of medicine and surgery — allopathy, as it is termed… that
would be to limit progress by establishing allopathy as the state system of
healing, and forbidding all others. This would be as foreign to ours system as
a state church for the cure of souls… To restrict all healing to that one
kind — to allopathy, excluding homeopathy, osteopathy, and all other
treatments — might be a protection to doctors in surgery and medicine; but
that is not the object of the act, and might make it unconstitutional, because
creating a monopoly.” 2
Just such a monopoly was created. For convenience, we can call it the Big
Pharma Cartel. It has money and powerful friends in government – who often
play bureaucratic “musical chairs” among agencies, big companies and
universities. They use that power to harass, jail and even kill their
competitors. We honor the memory of doctors Wilhelm Reich and Dinshah Darius,
among other victims of this witch hunt (as we honor the memories of those
earlier victims of witch hunts who were often Wise Women and Healers.).
In America, after decades of sporadic and arbitrary attacks on health food
stores, holistic doctors and alternative practitioners, a powerful groundswell
of public opinion surged in the early 1990s. People demonstrated at FDA
offices around the country, converged on Washington, flooded Congress with
letters and faxes. Those were heady days, when the political establishment
first took note of what has come to be called the Health Freedom Movement. The
result was congressional passage, without any negative votes, of the Dietary
Supplement Health and Education Act of 1994 (DSHEA). That law was supposed to
protect the right of nutrient purveyors to make truthful and not misleading
claims about the nutritional benefits of their products for the normal
structure and function of the body.
This did not, however, stop the attempts of cartel and its friends in power.
Numerous times since then efforts have been mounted in the media, through
cartel-financed schools and journals, and in the government, to discredit all
dietary supplements and all Complementary and Alternative Modalities (CAM).
The usual process includes fake science, smear and innuendo. In recent years,
add to that, very sophisticated attacks on web sites offering products or
information about nutrition and CAM.
The battle is being fought in each state, where now discredited
“quackbusters” attacked doctors wanting to practice advanced CAM
techniques; in the federal government where important therapies that can
benefit many people, such as the responsible use of silver in health 3, are
under attack; and on the international level where “harmonization” means
reducing our Freedom to some bland bureaucratic “minimum daily
requirement.” On the international level Codex Alimentarius, the World Food
Code, is the chief bureaucratic mechanism to undermine organic standards,
prevent people from knowing what foods are genetically modified – and which
are not – and otherwise make the Big Pharma Cartel agenda international
policy. Regional bureaucracies, such as the EU, NAFTA and the ominous North
American Union play an important role in imposing the harm of harmonization.
4
Recently, even the Journal of the AMA, JAMA, included a highly suspect
“meta-analysis” of carefully chosen “studies” to claim that taking
vitamins could be bad for your health! This article was strongly criticized
by Life Extension Foundation5 and others in the field, but the mass media
covered only the fake science, not the response. Literally tens of thousands
of good scientific studies prove the value of supplementation. It has been
suggested that those who trust the AMA and FDA should certainly not take any
vitamins, especially the mega doses many of us have used for decades. Then in
a few years, we’ll see who is still around to continue the argument!
Yes, at each turn, the attacks of the cartelists and bureaucrats have been met
with stiff public resistance. The attempt to water down organic standards gave
rise to a tidal wave of protest. The original FDA “structure and function”
regulation in 1999 was successfully opposed and the final rule was rather more
friendly to nutritional products. The public outcry in each of these cases was
similar to what is happening now with the FDA’s surreptitiously promulgated
CAM draft Guidance (“issued” on December 26th; no public notice until
February 26th; initially only a short comment period). The grassroots of the
Health Freedom Movement caught fire when the people learned that FDA’s
bureaucrats, under the guise of “just restating the law” were actually
setting the basis for handing over our supplements and alternatives to the Big
Pharma Cartel. 6
But the song continues, and big government representative Ted Kennedy, has
just introduced S-1082, a bill that may gut our Health Freedom. Curiously, we
had heard this bill was dead before submission and would not be submitted. As
soon as the current public outcry reached a very high level, along comes the
senator, with a bill intended to divert attention from the other
anti-supplement bills, Codex, the NAU and the anti-CAM guidance.
It is time to Kill the Kennedy Bill in Committee! While we won’t be diverted
from our vigilance of the FDA anti-CAM maneuver, it is important to react to
these other assaults on Health Freedom. We would like to see this bill killed
in committee. Better to knock it out in congressional committee than allow it
to waste our time. While comments directed at the FDA over its anti-CAM draft
guidance was the proper response, as required by the Federal Register notice,
this back-door effort by the senior senator from Massachusetts should be met
with a flood of messages to the chairman and the members of the oversight
committee that must approve the bill before it goes before the entire Senate.
That will be our strategy in the coming weeks. Of course, if we cannot stop it
in committee, it may be necessary to attempt constructive engagement with the
committee and senators, to amend the bill to protect supplements. Just this
step, according to postings on April 28th on the blog at Mercola.com, has been
suggested by leading nutrition attorney Jonathan Emord JD.
All of these multiple assaults are, of course, connected. They are connected
in philosophy, proponents and beneficiaries. Their proponents refuse to allow
us the freedom to make our own choices, deeming that their political power
gives them the authority to decide for us. We have had enough of such
deciders. They have given us a medical system that kills hundreds of
thousands each year. We reject the philosophy that “the leader is always
right;” that we should just shut up and take all the prescriptions Big
Pharma sells. We know that the cartel that benefits from all these rules and
regulations has plenty of money and jobs to bribe politicians and bureaucrats.
None of that matters when the people are alerted and vigilant! We assert our
“Right to heal and be healed.” 7 We will not be duped by false leaders,
naysayers and nitpickers. We are “mad as hell and won’t take it anymore!” The
time has come to assert thatfundamental right. We need, in both law and
fact, for this basic human right to be respected. We need an end to the power
of the cartel and its bureaucratic allies. And all this will come to pass
using the tools of modern communication, which will prove, I believe, in the
end, more powerful than cartels and politicians.
It does, however, depend on you. You need to support organizations like the
Natural Solutions Foundation, www.HealthFreedomUSA.org, which shows continuing
leadership and, in fact, broke the FDA anti-CAM guidance story. Like everyone
else who unmasks the face of the Big Pharma Objective, they are currently
being smeared and defamed through disinformation and innuendo. Don’t be duped
by disinformation any more than you are by bad science. It’s up to you to see
through to the core of truth and to make your voice heard. It is time to
dream of a world where each person has the right to heal and be healed. That
is the dream we need to have, for our dream to come true.
Ralph Fucetola JD
www.vitaminlawyer.com
Notes
1. See the Charter at http://home.earthlink.net/~lifespirit23/herbcharter.htm
2. North Carolina’s Supreme Court in State v MacKnight, 42 S.E. 580, 1902 at p
582.
3. See: www.silverfacts.com
4. See Dr. Laibow’s Nutricide at www.globalhealthfreedom.org
5. See: http://www.lef.org/featured-articles/consumer_alert_020307.htm
6. See “Take Action” at www.healthfreedomusa.org
7. See: http://www.lifespirit.org/wiltondec.html
This information is being jointly run by Mike Adams, NewsTarget: www.NewsTarget.com, a leading health and health freedom advocate. This unusual step is being taken by NewsTarget and the Natural Solutions Foundation to disseminate information about the concerted and on-going attack to which those organizations and individuals who are Speaking Truth to Power when the Power is Big Pharma and its marketing arm, the FDA. Please bookmark Mike’s excellent and informative site at http://newstarget.com/
Well-funded criminals attack health freedom groups with covert disruption campaigns
Mike Adams, Newstarget.com and Rima E. Laibow, Natural Solutions Foundation
Top health freedom consumer advocacy groups in the United States are being clandestinely targeted by organized disruption campaigns and “black PR” efforts. The apparent purpose of these campaigns is to discredit, disrupt and censor their natural health and health freedom political and educational efforts. Both the Natural Solutions Foundation (www.HealthFreedomUSA.org) and natural health news site NewsTarget (www.NewsTarget.com) revealed details today of distributed denial-of-service (DDOS) website attacks, database hacking attempts, personal and professional reputation internet smear campaigns and impersonation attempts, among other tactics. “All of these well-financed activities are clearly criminal in nature and violate free speech rights, libel and slander legislation and criminal statutes.” according to health freedom advocacy attorney, Ralph Fucetola.
The barrage of attacks seem to coincide with the recent success of both NewsTarget.com and the Natural Solutions Foundation in expanding their influence in the US and abroad. NewsTarget now reaches more than half a million readers each month with its outspoken reports on natural health solutions and consumer warnings about the dangers of prescription drugs and corrupt government agencies. The Natural Solutions Foundation is an international consumer advocacy group that fights the suppression of natural health options and the global contamination of food by CODEX (Codex Alimentarius).
Codex, as it is known, is a UN-sponsored international effort to regulate or outlaw herbs, vitamins and nutritional supplements and permit high levels of contamination of the global food supply by dangerous chemicals. Natural Solutions Foundation is following a strategy to allow nations to preserve natural health and protect their people from preventable diseases while avoiding Codex-related World Trade Organization (WTO) trade sanctions.
The HealthFreedomUSA.org website was recently knocked offline for several days due to a well organized DDoS attack (Distributed Denial of Service). Emails have also been blocked in an attempt to disconnect Rima Laibow, M.D., the Medical Director of the Natural Solutions Foundation, from her readers. Simultaneously, online donations and product sales were inactivated, denying the Foundation the donations and organic product sales which are its only source of funding. Drug and pornography-related response robots have also forced Dr. Laibow to close commentary on her very popular blog.
During the same time period, Mike Adams, the editor of NewsTarget.com, has been subjected to numerous personal attacks, including email smear campaigns, bogus inappropriate emails and a bizarre attempt to impersonate Adams by a covert operative who attempted to gain entry into the offices of the company that owns NewsTarget website and content, Truth Publishing International. Automated robot scripts have hammered NewsTarget-related message boards, attempting to fill them with pornographic images and bombarding administrators with garbage posts from bogus users.
“These actions are clearly criminal in nature and are being undertaken by organized, well-funded groups who desire to censor NewsTarget articles and deny the public access to information that tells them the truth about food, nutrition, medicine and health,” said Mike Adams, NewsTarget editor and consumer health advocate.
By attacking the Natural Solutions Foundation site and Mike Adams/NewsTarget, these covert actions specifically target some of the most effective forces in health freedom today. Significantly, they are designed to silence those groups which are most effectively educating people and countries about their rights to make their own health choices, regardless of whether or not those choices result in profits to the multinational corporations which attempt to govern our health and our freedoms.
Dr. Rima Laibow is an MD who has practiced drug free psychiatry and medicine for 37 years since her graduation from Albert Einstein Medical College in 1970. She is a recognized pioneer and medical innovator, teacher and health freedom activist who has been working in the natural medicine an health freedom areas for decades while practicing drug free psychiatry and medicine full time. Her concern over the impact of the illness care industry, including Big Pharma, led her to close her private practice of medicine in 2004 in order to devote herself full time to securing freedoms for natural health and personal health choices on a global basis.
Along with Major General Albert N. Stubblebine III (US Army, Ret.) she founded the Natural Solutions Foundation and, working with a group of pro-health lawyers, crafted a science-based international legal solution to the global threat of Codex. Briefing Heads of State, Ministers of Health and others around the world, the Natural Solutions Foundation has rapidly become a major force in the global struggle to retain the right to choose and use natural health options including clean, uncontaminated food, high potency dietary supplements and other non-drug health strategies. The Foundation is sponsoring a Citizens Petition which is a legal tool to challenge the 1995 decision of the US Government to “HARMONIZE” with Codex in preference to US Domestic regulations. Over 40,000 Americans have signed this document calling the FDA and USDA to heel over Codex.
The Natural Solutions Foundation is also mobilizing public support to prevent the FDA from adopting a “Guidance” on CAM (Complementary and Alternative Modalities) which opens the door to criminalizing all natural health practices and prodcts. More than 73,979 Public Comments have been submitted to the FDA through a special comments page on their website since they requested this activity 5 days ago even though the submission link has been severed several times during that period.
National health policy around the world has been positively impacted by their efforts. For example, at the latest Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU, Chiang Mai, Thailand, November 2007) the document provided by the Natural Solutions Foundation allowed health-friendly countries to override the vigorous objection of the US, Australia, New Zealand and the EU and prohibit the addition of the dangerous toxin, fluoride, as an additive to baby formula for healthy children. Fluoride causes bone cancer, leukemia and other cancers, increased tooth decay, bone breaks, endocrine damage, brain damage and poisons other major organ systems.
Dr. Laibow’s definitive Codex lecture, Nutricide, has been seen by more than 119,000 people on Google Video alone. Tying together the origins of Codex and the Nazi death camps, this riveting video has become a viral phenomenon on the internet with global web postings, translations and email sharing.
The Natural Solutions Foundation is welcomed by decision makers around the world as a non-commercial health advocacy organization. Dr. Laibow and General Stubblebine recently briefed the President of India on Codex in an extended private session. Dr. Laibow was the featured speaker at an Indian government meeting for an organization representing 950,000 Indian farmers, addressed the assembled Health Ministers of eastern, southern and central African nations and has met with dozens of decision makers in their own countries in Asia and Africa.
The Natural Solutions Foundation attends numerous Codex meetings, lobbies for health and health freedom, alerts readers to health freedom issues and natural health options and reports on them extensively. Her articles, interviews, blogs and emails are widely read and disseminated by natural health advocates and supporters around the world.
Neither Dr. Laibow nor General Stubblebine receives any salaries or royalties from their health advocacy work or the sales generated by their virtual store, Organics4U, at www.HealthFreedomUSA.org/store
Mike Adams is the creator of numerous free nutritional guides and health-related interviews that are enjoying widespread popularity. His Honest Food Guide (www.HonestFoodGuide.org) has been downloaded more than 800,000 times. Adams is also the creator of the free Natural Health Library (www.NaturalHealthLibrary.com) and the hugely popular free online reference site www.HealingFoodReference.com . Adams is also the executive director of the non-profit Consumer Wellness Center (www.ConsumerWellness.org), an organization dedicated to enhancing pre-natal nutrition, ending censorship of nutritional supplements and other notable achievements. Mike Adams receives no salary and no royalties from his health advocacy work.
NewsTarget.com and the Natural Solutions Foundation work independently and do not pursue any projects jointly. However, together they are both proving to be highly successful in attracting grassroots activism and readership among people who wish to protect their freedoms and their access to accurate information about health.
Organized and virulent attacks by groups and government agencies targeting effective health freedom groups, authors and individuals have a long and disgraceful history. Covert disruption attempts have been used against many health freedom advocates. The Life Extension Foundation, for example, was targeted and raided by the FDA and its founders charged with 89 federal crimes. When the LEF fought back vigorously (and expensively!) in court, all charges were dropped!
The history of conventional medicine is rife with blatant attempts to suppress, silence and discredit anyone daring to teach people the truth about health, nutrition and medicine. The American Medical Association, for example, was twice found guilty of conspiracy to destroy chiropractic medicine in U.S. federal courts. Rife machines were destroyed. Wilhelm Reich’s books were publicly burned by the FDA and his devices destroyed. Cancer remedy creator Harry Hoxsey was hounded (and almost assassinated) by thugs linked to conventional medicine.
The true history of armed FDA raids, kidnappings, and other dubious actions taken against health freedom pioneers is revealed in Mike Adams’ new book, Natural Health Solutions (www.TruthPublishing.com). Attacks against Adams were stepped up following the release of this book which documents the real history of Big Pharma and its links to Nazi Germany: Companies like Bayer, BASF and Hoechst are the offspring of IG Farben, the Nazi corporation that conducted medical experiments on prisoners in the Auschwitz concentration camp and was dissolved by the Nuremberg Tribunal. Attacks against the Natural Solutions Foundation likewise intensified with the publication of “The Killing Ground of Codex“, a detailed examination of the links between Codex Alimentarius and the Nazi drug companies continuing until the present day.
“There is no question in my mind that drug companies are funding these covert attempts to target health freedom groups in an effort to destroy or discredit them,” said Adams. “As the world’s richest corporations that rely on the continued ‘disease-ification’ of the world population in order to exploit people for profits, drug companies have the motive and the means to launch such attacks against those who threaten their profits and control. The more we reach consumers with honest information about the dangers of pharmaceuticals and the safe, natural cures available from nature, the more we are attacked,” Adams said. “And rather than facing us in public with an honest debate about health, they engage in covert operations to get what they want. It’s the same way they control Congress and the Food and Drug Administration.”
Dr. Laibow notes that since drug companies, which promote the use of dangerous and often deadly products which suppress symptoms by poisoning the body (like the deadly Cox-2 inhibitors Vioxx and Celebrex) could not win an honest debate, they use stealth, science-for-hire, poison press propaganda and covert attacks like the ones to which Mike Adams and the Natural Solutions Foundation are currently being subjected.
Despite the ongoing attacks, both the Natural Solutions Foundation and NewsTarget.com continue to publish daily articles on health freedom, consumer advocacy, revelations and condemnations of the actions of drug companies, the FDA, the USDA and other groups which fail to protect the public. Ironically, both organizations have surged in popularity and garnered new support because of these attacks.
For more information:
Natural Solutions Foundation: www.HealthFreedomUSA.org
NewsTarget: www.NewsTarget.com
Could It Be That All The Problems Are Coincidence?
A couple of days ago The Natural Solutions Foundation sent out an Action Alert telling you that the FDA is at it again. Their “Proposed Guidance on CAM” will classify all natural therapies as “Medical Practices” so only licensed physicians will be able to practice them. Then the supplements and products used in those practices become “untested drugs” which are, in the US and elsewhere, illegal. Not only that, I can tell you as a physician that deviations from “practice guidelines” or “treatment algorithms” are increasingly cause for doctors to have their licenses pulled so few doctors will offer those modalities.
The Comments page , (http://www.democracyinaction.org/dia/organizationsORG/healthfreedomusa/campaign.jsp?campaign_KEY=7185) I set up for you to use to send your comments electronically to the FDA during the public comment period (which ends on April 30) was working perfectly and, at last count, 11,030 people had sent comments to the FDA using that page.
And then the emails began coming in that said things like, “When I click the “submit” button, I get an ‘Error 404’ message.” and “When I clicked on the link in your email, I got a “Page no longer available” message and similar emails.
Connect the Dots!
Dot:
On March 14 of this year our site, www.HealthFreedomUSA.org, was “locked” by our hosting company hours after we made it known that the huge number of drug-related deaths which are the leading cause of death in every developed country in the world fit in perfectly with the explicitly stated genocidal agenda of multinational and international organizations from the Council on Foreign Relations to the World Health Organization. We pointed out that this fits perfectly with the apparent underlying Codex agenda (https://staging.drrimatruthreports.com/index.php/?p=322), coming as it does straight from Nazi Germany. (Check out the Nutricide Video on our home page, www.HealthFreedomUSA.org if you haven’t seen it! Email that link, too.)
Dot:
A temporary page telling people what happened after our site went down was mounted by our webmaster. Within hours his server and all of his sites were off the Internet because of a concerted, organized and illegal attack on our site and his hosting server. When he took our temporary site down, the attack ceased almost instantly and his sever and sites were back on line within minutes.
Dot:
Our Action Alert on the proposed New York legislation (https://staging.drrimatruthreports.com/index.php/?page_id=351) which will limit access to nutrients and supplements in that state was number 1 in Google’s ranking on the topic one day and suddenly disappeared from the Internet search engine altogether overnight!
Dot:
More than 11,000 people have responded to our urgent request that they file their objections to this latest FDA end run around DSHEA (the 1994 law which says that supplements and herbs are foods and, as such, are presumed to be safe). Our Action Alert emails on the topic have been widely circulated and people are using this opportunity to create another uproar like the one that prevented Congress from taking away our right to supplements in 1994 and brought us DSHEA!
Dot to Dot to Dot:
I Can See the Picture!
I think it is reasonable to conclude that our vigorous response and success is not particularly welcome to the FDA and their friends. And that means that we need to intensify our successful response right now! We only have until April 30, 2007 to let the FDA know that We, the People, want our health products, our health freedom and our self determination. The FDA also needs to know that we want Public Hearings on these issues and that we are willing to make our will loud and clear.
Here’s Your Part
You have been doing a great job of sending your comments to the FDA and circulating this information to your circle of influence. It may be hard to take in but if this “Guidance” goes through, there will be no more legal natural health and wellness modalities. There will be no more natural health and wellness products.
Our nutrients, if we are permitted any, will look very much like the low potency, no impact nutrients permitted in Europe under the Codex-Compliant European Food Supplements Directive (using any other nutrients in any other dosages is a crime). Our herbs, if we have any, will look very much like the very, very short list of herbs permitted ONLY FOR TRIVIAL COMPLAINTS in Europe under the European Medicinal Herbal Products Directive (using any other herbs for any other reasons is a crime). In other words, Big Pharma, like Big Brother at the end of George Orwell’s chillingly prophetic “1984” will have won.
We are That Close!
We are that close to loosing natural medicine. We are that close to loosing our health freedom.
It is imperative that you submit your comments to the FDA. If you value your health or your freedom (or both) you have only a narrow window of opportunity to raise your voice with all the other voices shouting for our right to make our own health decisions.
Use this link to access the page where you can submit your comments : http://www.democracyinaction.org/dia/organizationsORG/healthfreedomusa/campaign.jsp?campaign_KEY=7185
If there is a problem wit the link, write to me with your information at dr.laibow@gmail.com and I will personally make sure that your comments are submitted to the FDA. Every one of them!
After you have submitted you comments, the next step is critical. Spend some time contacting all of the people in your circle of influence and, with a short note at the top of the email, explain how dangerous this threat is, how short the window of opportunity is and what the consequences will be if the FDA and Big Pharma succeed this time around. Please include the makers and sellers of your vitamins, minerals, etc. as well as the practitioners whom you know in your emails. Ask people, practitioners, health food stores, organizations and companies to alert their customers, patients, suppliers, friends, etc. We need millions of responses and we CAN get them if we all work together on this.
Oh, and please, don’t forget to write to me to let me know if you have any further problems with the links or the sites. We will fix them if you do.
Actually, I take heart from these attacks: if we were not effective, there would be no need for sabotage!
Remember, the FDA’s goal is simple: through a “Guidance” about the regulation of “CAM” (which they conveniently define as “Complementary and Alternative MEDICINE” instead of “Complementary and Alternative Modalities” the FDA hopes to serve the interests of Big Pharma by eliminating all CAM practices and products. ALL of them.
Criminalizing Natural Health
The FDA is using a legal ploy to make all natural health criminal in either one way or another. You can’t engage in it if you are not a physician and you cannot use the products even if you are. That’s very similar to the laws recently introduced in Australia (5 year prison sentence for using, providing to another person or teaching the use of nutrients) and India (illegal to practice or teach acupuncture, energy healing, sound therapy, etc., etc.). Neither law passed but they will be back in Parliament again. It’s the same process: marginalize, then criminalize all competition to the deadly, expensive and oh-so-useful drugs!
In your email to your circle of influence, please remember to Include a link to the Natural Solutions Foundation website (www.HealthFreedomUSA.org ). Tell them that we are protecting their health freedoms and ask them to lend their support to the health freedom battle which threatens to criminalize natural health! Let them know that when you click on this link, http://www.democracyinaction.org/dia/organizationsORG/healthfreedomusa/campaign.jsp?campaign_KEY=7185, your comments will be automatically registered on the FDA site.
5,000,000
That’s our goal. Two weeks, five million comments to the FDA, all asserting our fundamental right to control our own health. Manufacturers, distributors, health food stores and natural practitioners pay close attention: the FDA is in the process of regulating your business out of existence. By April 30. If you value your work and your livelihood, ACT NOW!
Here’s that critically important link:
We are collectively doing a GREAT job. That’s the reason efforts to silence us crop up. We are not silent because we are right: our health and our freedom is worth speaking out for and we are doing it!
We ARE the Ones We Have Been Waiting For!
Oh, yes. One other thing: The lawyer who wrote this comments document did it for free. Our other legal consultants work for free. I work for free. General Stubblebine works for free. Our wonderful volunteers and Board Members accept no compensation. Everyone else who is providing services wants to be paid for the work they do for us. And rightly so, by the way. So don’t forget to feed the health freedom kitty by making a tax deductible donation (https://staging.drrimatruthreports.com/index.php?page_id=189) or shopping at our all-organic store! Thanks for all your wonderful support.
Yours in health and freedom,
Dr. Rima
Rima E. Laibow, MD
Medical Director
Natural Solutions Foundation
www.HealthFreedomUSA.org
04/06/07
Let CAM Continue to Develop Freely
To: Food and Drug Administration
From: Natural Solutions Foundation
Re: FDA Docket No. 2006D-0480
These comments are submitted by Major General Albert N. Stubblebine, Rima Laibow, MD and Ralph Fucetola, JD on behalf of Natural Solutions Foundation with regard to the Food and Drug Administration’s draft “Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration.” They are submitted with reference to the request of FDA for comments on the proposed Guidance stated at: http://www.fda.gov/OHRMS/DOCKETS/98fr/E7-3259.htm .
The Natural Solutions Foundation is a tax exempt, recognized nongovernmental organization active in the United States and internationally, communicating Natural Solutions to the many health problems caused by government intervention, with emphasis on FDA and Codex Alimentarius over-regulation of natural foods and supplements.
Complementary and Alternative Modalities (CAM), including traditional remedies and nutrition to achieve and maintain a healthy status, are preferred by many Americans to so-called “standard” allopathic medical treatment, primarily due to the well-documented iatrogenic death and disabilities, the dangerous side effects and persistent failures of the so-called “standard” model. The Dietary Supplement and Natural Remedies market has grown to over $28 billion dollars annually as Americans consistently vote with their dollars choosing CAM products out of un-reimbursed funds.
The Foundation urges the FDA to take into account an important legal distinction that FDA appears to ignore totally in the draft Guidance. That distinction is between “treatment of disease” and “therapies that may benefit.” In keeping with that distinction, explained below, it is suggested that the Guidance be titled, “Guidance for Industry on Complementary and Alternative Modality Products and Their Regulation by the Food and Drug Administration.” CAM is not “medicine”, does not rest in medical models and allopathic methods and does not seek to be considered “medicine.” In fact, CAM seeks to shed the appearance of “medicine” which is not in keeping with CAM traditions and activities.
We request the FDA take the following steps: (1) hold public hearings on the proposed Guidance; (2) formally revise the Guidance title to replace the word “Medicine” with “Modality” and (3) use of the terms “therapy” and “therapeutic” with reference to Complementary and Alternative Modality health practices, instead of the words “treat” and “treatment of disease” which are used exclusively in the draft Guidance. The terms “treat” and “treatment of disease” are, in fact, antithetical to CAM therapies.
CAM health practices can be generally defined as traditional or other practices that are used by individuals, often for self-help, to achieve and maintain a healthy status, either on their own or complementary to standard medical care. These practices do not include the potentially dangerous use of invasive techniques and toxic drugs that are the sole province of licensed medicine. They do, however, include developing therapies and nonstandard approaches that are outside the scope of licensed medicine. Such approaches as Nutrition, Homeopathy, Hands-on-Healing, Magnetics, Sound Health, Energy Therapies, Biofeedback, Meditation, Breath Work, Reiki, Chi Gong, Tai Chi and Herbology are examples of complementary and alternative therapeutic practices. Traditional Chinese, Ayurvedic medicine or folk remedies and “Dr. Mom” home remedies are also examples of CAM practices. These practices aim, in the words of the late Philip J. Hodes, PhD., at “more efficient physiological integration and function of the human organism, leading to optimal wellness.” This definition is the polar opposite of non CAM practices which seek to suppress or ameliorate symptoms without an approach to optimal wellness.
The terms “therapy” and “therapeutic” do not occur, for example, in the context of the Dietary Supplement Health and Education Act of 1994 (DSHEA). Rather, that statute, passed by unanimous Congressional Consent, tells us that Dietary Supplements may not “diagnose, treat, cure or prevent” any disease. It does not specifically forbid the use of the word “therapy” (or “therapeutic”). Under the Supreme Court’s rule in the Thompson v Western Medical case, we should expect that these words would not be forbidden by the Courts and should not therefore be overtaken by the regulators.
Further, the Code of Medical Ethics of the American Medical Association also acknowledges an independent use of the term “therapy.” The original Hippocratic Oath, with its injunction to “Do no harm.” has been replaced by a complex Code detailing the relationship between physician and patient and alternative practitioner. Changes made during the early 1990’s were inspired by anti-trust lawsuits brought (and won) during the 1980’s by chiropractors and other non medical practitioners. These changes are just now becoming recognized by regulators and courts.
While “treatment which has no scientific basis” remains condemned (Opinion 3.01), under Opinion 3.04, physicians are free to “refer” a patient “for therapeutic or diagnostic services to another physician, limited practitioner or any other provider of health care services permitted by law to furnish such services, whenever he or she believes that this may benefit the patient.” Thus, unscientific “treatment” is distinguished from “health care services permitted by law.” “Treatment” — which means the use of standard medicine and surgery to “cure” disease — is distinguished from other health care services (therapies) which need only meet the lesser “may benefit” standard. While physicians “prescribe” treatments for disease, therapies that may benefit may be subject to “referral” thereby further indicating the distinction. Thus, for example, Dietary Supplements that support normal structure and function to support therapeutic outcomes can be seen to complement licensed medicine, but not to be held to its strictures, nor limited in its practice to licensed physicians. Since such therapies are not prescription services, members of the public may choose such services without the permission of their physician. Purveyors may restrict sale of therapeutic products to physicians, complementary practitioners, exercise and health care professionals, although they should not be required to do so.
We have analyzed the word “therapy” and the similar word “therapeutic” because these words are not forbidden by DSHEA and are referenced by the AMA Ethics Code. We recommend “Therapeutic Nutritionals” for alternative practices centered on Nutrition. We recommend the use of the qualifying word, “Nutritional” in this context to make it completely clear that the practitioner is not offering “treatment of disease.”
The claims made for Therapeutic Nutritionals must, of course, be allowed Structure and Function Claims. Thus, for example, under current law as interpreted by the FDA, one cannot claim that a nutrient lowers cholesterol levels – since there is now a “disease” of hypercholesterolemia – but can claim that a nutrient maintains normal cholesterol levels for persons with normal cholesterol. A purveyor may say that a certain combination of multivitamins was designed to maintain normal structure and function for a person with diabetes, but not that the combination “treats” diabetes or affects the blood sugar level. Similarly, any Health Claim made for any alternative practice must meet the FTC standard of “truthful and not misleading” and must be based on standard commercial substantiation criteria.
CAM products are intended to benefit normal structure and function and are not prescribed as treatment for medical or psychological conditions, nor for diagnosis, care, treatment or rehabilitation of individuals, nor to apply medical, mental health or human development principles.”
As the High Court said in Thompson, “We have previously rejected the notion that the Government has an interest in preventing the dissemination of truthful commercial information in order to prevent members of the public from making bad decisions with the information. * * * Even if the Government did argue that it had an interest in preventing misleading advertisements, this interest could be satisfied by the far less restrictive alternative of requiring … a warning…”
What is the proper level of substantiation for CAM nutrient or health claims? It is not the “significant scientific agreement” required of drug claims, but rather, the general “competent scientific evidence” standard that applies to all commercial claims. That does not imply that purveyors need to have multiple double-blind experiments (as may be required for drug approval). Substantiation merely needs to be competent and scientific. We urge this to include research studies (which is when scientists review the work of others and apply it to specific questions) and clinical trials (which may be as formal as double-blind, placebo controlled investigations but need not be, since multiple variables, like those involved in CAM practices designed to promote optimal health, are not well studied by double-blind, placebo controlled investigations) as well as traditional knowledge, clinical case studies, observational reports and clinical experience. All of these sources of information and experience have a role to play, but ultimately, such substantiation must rest on the informed professional opinion of some credentialed or appropriately experienced person who can (in the case of Dietary Supplements, for example) sign onto the Structure and Function Claims Notice to the FDA, attesting that “the notifying firm has substantiation that the Statement to which this Notice applies is truthful and not misleading.” (Regulations under 21 U.S.C. 403(r) (6)).
The Natural Solutions Foundation favors a market approach to these issues and urges the FDA to reduce regulation to those minimum levels that will encourage the continued rapid development of CAM approaches. Especially when dealing with Dietary Supplements and Traditional Remedies, we are dealing with foods which, as foods, are presumed to be safe. There is no need for the high level of regulation that is required for the dangerous and invasive drugs and techniques of so-called “standard” medicine. Even with this stringent level of oversight, drugs are a major cause of death in every developed country while CAM remedies are an insignificant-to-absent cause of death world-wide. Rather, this is a situation where the public is best served by a policy of Laissez-Faire: allow CAM to develop freely in the public interest.
Throughout the world today people are looking to traditional methodologies and leading-edge CAM techniques because they offer alternatives to toxic, expensive drugs with their dangerous side effects, un-manageable and unreasonable costs and other invasive technologies of modern medicine. This search for alternatives is protected by the fundamental right of individuals to communicate and learn; to heal and be healed. This has been settled law for over a hundred years.
“The state has not restricted the cure of the body to the practice of medicine and surgery — allopathy, as it is termed, — nor required that, before anyone can be treated for any bodily ill, the physician must have acquired a competent knowledge of allopathy and be licensed by those skilled therein. To do that would be to limit progress by establishing allopathy as the state system of healing, and forbidding all others. This would be as foreign to our system as a state church for the cure of souls. All the state has done has been to enact that, when one wished to practice medicine or surgery, he must, as a protection to the public [not to the doctor], be examined and licensed by those skilled in surgery and medicine. To restrict all healing to that one kind — to allopathy, excluding homeopathy, osteopathy, and all other treatments — might be a protection to doctors in surgery and medicine; but that is not the object of the act, and might make it unconstitutional, because creating a monopoly.” North Carolina’s Supreme Court in State v MacKinght, 42 S.E. 580, 1902 at p 582.
Costs, safety and, most of all, liberty, require that the distinction be made and maintained by the FDA between “treatment” and “therapy” if the US Constitution and public are to be served.
Dated: April 6, 2007
Respectfully submitted,
Maj. Gen. Albert N. Stubblebine III,
(US Army, Ret.)
Rima Laibow MD
Ralph Fucetola JD
For: Natural Solutions Foundation
www.HealthFreedomUSA.org
Ref: Federal Register: February 27, 2007 (Volume 72, Number 38
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