Letter to about their misleading Codex article.

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Letter to Urban Legends (

By Rima E. Laibow, M.D., Medical Director of the Natural Solutions Foundation

This is a letter written by Rima E. Laibow, M.D., in response to Ms. Mikkelson's factually flawed article about Codex on It is lengthy because it has to be in order for the most accurate supporting evidence to be provided to backup Dr. Laibow's conclusion about Codex. We have yet to receive a reply.

To: Barbara Mikkelson, Urban Legends Reference Pages (

Re: "Vitamin See"

Date: February, 2005

I am a regular visitor to because I find your information helpful and, in general, accurate. However, in the piece referenced above there are both serious factual errors and, even worse, an implication of dismissal of issues which are not only real, but very serious threats to the health and health freedoms of virtually everyone in America (and indeed the rest of the planet).

Here are the real facts:

S722 and HR3377 are pieces of legislation which were neither enacted nor defeated during the 108th Congress and are therefore moot.

However, the members of Congress who introduced and co-sponsored these bills have indicated repeatedly that it is their intention to reintroduce these bills (which will give them new numbers) within the next few months. Hence, the attempt to gut DSHEA is alive and well.

If these reintroduced bills are passed, supplements (including vitamins and minerals) will be classified as drugs, not foods. (By the way, your author makes a distinction between supplements and vitamins and minerals which to me, as a practicing physician using nutritional medicine, is totally incomprehensible.) Since natural molecules like niacin, Vitamin C, CO-Q-10, etc. are not patentable, no one will be likely to put up the hundreds of millions of dollars necessary to take a molecule through the drug approval process (drug testing currently runs between $100 Million and $800 Million per drug to get to FDA approval) since, without a patent there is no way for a company to recoup its expenses.

Pharmaceutical houses can recoup their losses through advertising and physician "education" which allow massive profit margins in their pricing. This set of financial obstacles mitigates successfully against natural substances being brought through the drug approval process.

So if the new legislation is introduced (as intended) and passed (as intended), we will, in fact, have lost access to clean, inexpensive and a rich array of dietary supplements, including vitamins and minerals.

However, if the gutting of DSHEA does not take place, then the Codex Alimentarius limitations on natural substances and nutrients, as well as its other negative impacts on human health and health freedom will impact us all very negatively.

It is only partly correct to say that Codex Alimentarius is a voluntary regulatory option. In a court of law in the United States is considering a case in which a person is told to hand over their wallet to a mugger who is holding a pistol to his temple and who says, "Give me your wallet or I will pull the trigger.", if the mugger's defense is, "Your Honor, I did not rob this man, he gave me his wallet voluntarily" the court would hold that the man with the wallet was unduly coerced and therefore he did not act in a voluntary manner.

The same hold true with Codex Alimentarius. Currently, it is a "voluntary" standard. However, if the standard is not adopted by countries who are members of the World Trade Organization (as we are), those countries will be punished with trade sanctions across the economic board. So the gun is at the temple and the wallet is being extracted under this scenario. Australia, Canada and the EU have already accepted "harmonization" with Codex Alimentarius, the so-called "voluntary" standard.

Under these voluntary standards, in fact, only 28 vitamins, minerals and supplements will be permitted and maximum permissible doses have been set for these 28 substances which are NO HIGHER THAN THAT FOUND IN FOOD. This goes against good science and good sense. There is a mass of clinical experience and non-industrially controlled science which makes it clear that the chronic, degenerative diseases which are crippling and killing us at increasing rates (and at younger ages than ever seen before) and that the appropriate treatment strategies for them are nutritional interventions. These nutritional interventions often require the use of large doses of nutrients to correct the underlying biochemical/metabolic cause of the degenerative disease.

In the United States, any substance not specifically forbidden is allowed as a nutritional supplement. Under Codex Alimentarius, any substance and dosage not specifically permitted is forbidden. The net result: only 28 ultra low dose vitamins and minerals are permitted under Codex Alimentarius. So the claim that the access of Americans to vitamins and minerals is threatened by Codex Alimentarius is absolutely true.

However, your article is wrong on yet another significant count: Right now, Codex Alimentarius is "voluntary" as discussed above. That changes dramatically in July [note: this letter was written before the July 2005 ratification of the Codex Alimentarius Vitamin and Mineral Guideline]. According to the terms of the treaty which the U.S. Congress signed when we became a member nation of the World Trade Organization, once a set of regulations like Codex Alimentarius is ratified, it no longer has a voluntary, optional regulatory status. Once ratified, Codex Alimentarius takes on the force of law in member countries. Codex Alimentarius is due for ratification this July. At that time, there will no longer be even the pretense of "voluntary compliance".

Codex Alimentarius is much more than the restriction of natural substances, however. It also legalizes GMOs (some of which require the application of pesticide to germinate), increases the permissible levels of pesticide toxins and chemical residues to levels now known to be associated with degenerative diseases and a sharp increase in cancer and birth defects. Codex Alimentarius also sharply restricts or eliminates most medicinal herbs and limits the conditions which can be treated using medicinal herbs to a small number of trivial ones.

It effectively eliminates all traditional medical approaches like Tibetan Medicine, Ayurveda, tribal remedies, etc., leaving only pharmaceutical options legally available to the world's people, most of whom cannot afford to purchase these drugs (even if they were the appropriate choices).

Codex Alimentarius also legalized and mandates the irradiation of food despite serious scientific question about the safety of exposing protein to ionizing radiation.

In short, Codex Alimentarius is a major threat to the health and well being of the planet and, while it is technically "voluntary" at this point it will soon become mandatory following the ratification of Codex Alimentarius in July, 2005 [note: this letter was written before the July 2005 ratification of the Codex Alimentarius Vitamin and Mineral Guideline]. I hope this clarifies the issues and that you will amend and correct your entry on these items.

Thank you,

Rima E. Laibow, M.D.



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