NIH Response: IOM Report on Vitamin D

As we speculate on the many options of institutions to respond to the Institute of Medicine report on vitamin D, the most important is how the NIH and its various departments respond.  Driving the response most likely will be the Dietary Supplement and Health Education Act of 1994.  This act does several things, but the most important is to limit the authority on dietary supplements by the FDA.  As long as a dietary supplement makes no claims about healing or preventing disease, then preapproval for sale by the FDA is not required.  So is vitamin D a nutrient or a drug.  The DSHEA states that anything shown to prevent or cure disease most be defined as a drug and regulated as such.  This is where the language on vitamin and nutrient labels gets tricky.  You can suggest that the nutrient may help your body to heal, but you cannot state outright that the nutrient will cause you to heal or prevent a disease.

I really think that Dr. Robert P. Heaney, MD had this in mind when he did the presentation on the physiological action of vitamin D.  The title is “Vitamin D: Nutrient, not a Drug.”  But by definition according to DSHEA, vitamin D does prevent and treat disease, therefore is a drug.  You can watch the presentation through Grass Roots Health and UCSD tv.  Dr. Heaney makes the argument that vitamin D does not heal disease.  The vitamin D allows the body to respond with its natural healing processes or innate immunity.  Vitamin D does this by opening the DNA library that is contained in every cell.  This was confirmed in August this year by a report from Oxford University saying that there are over 2700 genes or more than ten percent of the genome with vitamin D pathways.

There is a mountain of research that shows that vitamin D does cure and prevent disease.  The only reason that the FDA may not be able to step in and regulate this nutrient as a drug is because of the history of this nutrient and the general safety that has been shown through the use of cod liver oil over many decades.  Of course the drug manufacturers will not like the fact that they could have large market losses because of the reduced amount of disease.  The other issue of course that must be considered by government is the impact on the economy with a healthy population.

I know the statement above may be counter intuitive when thinking about health and the economy.  However, the largest segment of our economy is the health segment.  If disease were reduced by twenty five percent then most likely the health segment of the economy would be reduced accordingly.  With the present state of the economy in general this could be disastrous.  You will not get to decide if you would rather be healthy or have a healthy economy.  The government or more specifically, Secretary Kathleen Sebelius of Health and Human Services will decide this for you.  I suspect through the guidance of the President since she reports directly to him.  Is there any evidence that the government considers the economy more important than your health?  Yes the predecessor of Sebelius was Michael Leavitt and his number four principle was ‘markets before mandates’.  His last principle of nine was to ‘value life.’

With the economy more important than mandated health, I suspect that there will be an attempt to limit the understanding of vitamin D for the general population.  However, there may be significant guilt because of the length of time that this information has already been suppressed.  Or if you prefer, the understanding of vitamin D has been ignored.  Saying that it has been ignored is a much nicer way to say that we have maintained a medical economy of trillions of dollars from your bad health over the last fifty years.  In other words, you had jobs, but your health could have been much better – a true conundrum!  Mandate serum testing of the entire population or let them remain in a much worse disease state to maintain the medical economy.  I’m glad that is not my decision.  You can make your own personal decision about maintaining your vitamin D at a summertime level all year.  – Pandemic Survivor


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