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To further understand the danger of using Risk Assessment to test nutrients, one must understand how the process works. Dr. Rima Laibow gives an excellent synopsis:
First a group of test animals, mice, rats, rabbits, et cetera, are given increasing amounts of the toxin of interest. The dose is increased until half of the animals are dead. The dose at which 50 percent of the test animals die is called the Lethal Dose 50 (LD50). A similar dose is extrapolated for humans.
Next, the other end of the dose spectrum is investigated by giving test animals smaller and smaller doses until no impact can be identified from the dose of the toxin to establish the Maximum Upper Limit (MUL). The MUL is divided by a safety factor, typically 100. The dosage that results is called the Maximum Permissible Upper Limit.[1]Here of course, the “toxin” being administered is a nutrient -- a vital component of human life. This in itself is a contradiction. Add to that the fact that the Maximum Upper Limit is set at the level where there is no impact, then further reduced by a safety factor division, and you begin to see the purpose of banning nutrients coming to fruition.
Although the synopsis given above is admittedly a simplistic one, the end result is as described above -- the dosage of the substance being tested is reduced further and further until no impact (positive or negative) is observed, this figure is then divided by another number (depending on the evaluation but usually 100) which results in the Maximum Permissible Upper Limit. Already, at the end of such a procedure, dietary supplements are reduced to a state where they are virtually useless. Yet the insanity does not end there.
The goal of reducing nutrients to virtually nonexistent levels continues with the creation of Maximum Permitted Levels. Dr. Rolf Grossklaus, Chairman of the Codex Committee on Foods for Special Dietary Uses (one of the Codex committees that deal with nutrition) and Director of the German Federal Institute for Risk Assessment,[2]brought to the committees’ attention what is labeled as the Global Expectable Average Daily Diet.[3] This is essentially what is estimated to be the average diet of all human beings in the world and their nutritional intake as a result of that diet. However, the Global Expectable Average Daily Diet does not take into consideration populations with lower nutritional intake such as Third World countries. It is simply an average that everyone is lumped into.[4] But because populations with very low levels of nutrient intake are not properly included in the estimate, this leaves only those countries where higher levels of nutrient intake exists, falsely providing results that suggest the Global Average Daily Diet is higher than it is.
Essentially, the levels of acceptable nutrient intake will be ratcheted down based on the populations with the highest amounts of nutritional intake. This process removes countries with low level intake of nutrition from the equation, providing Codex with a higher Global Average Daily Diet which it will then use to reduce the levels of vitamins and minerals even further. [5]
This stance is enumerated in the Codex “Guidelines for Vitamin and Mineral Food Supplements” when it is stated, “Most people who have access to a balanced diet can usually obtain all the nutrients they require from their normal diet.”[6] Such a statement is laughable to anyone who has studied health and nutrition, because anyone who has done so knows very well that even in the most highly developed countries in the world we do not receive nearly enough nutrients from our daily diet. Yet Codex is working on the supposition that everyone eats the same diet (on average) and that they get all the nutrition they need from it.
Nevertheless, the Global Expectable Average Daily Diet is then used to subtract the amount of nutrition we allegedly receive from our diets from the Maximum Permissible Upper Limit set by Codex. The value that results is the new Maximum Permitted Level,[7] -- a value that lowers the acceptable level of nutrients even further. As Paul Anthony Taylor illustrates:
If the upper safe level for vitamin B6 is calculated to be 10mg, as recommended by the UK’s Expert Group on Vitamins and Minerals, and the average daily intake of vitamin B6 from food is calculated to be 2.9mg, as was stated to be the case for men in the UK’s National Diet & Nutrition Survey in 2003, then the “maximum permitted level” of vitamin B6 in supplements could potentially be set by regulators at a mere 7.1 mg. [8]The rationale is that since we are already receiving a certain amount of nutrients from our food, we must take that amount of nutrients into consideration when establishing a “Maximum Permitted Level” for nutrients in general. Hence the lowering of the “safe” levels.
It should be noted that, while the differences between the Upper Safe Levels and Maximum Permitted Levels are slight, they are still important. One of the main and most important differences is the method by which Maximum Permitted Levels are reached with the further lowering of nutritional content using the Global Expectable Average Daily Diet mechanism. But even semantic differences play a role in the reduction of nutrients as the designation of “Maximum Permitted Level” carries with it a more authoritative and restrictive tone, an important aspect when dealing with scientific, legal, and regulatory labeling. MPLs deal with Maximum Permitted Levels, abandoning the cover language of safety guidelines and moving its motives more out in the open.
The process of establishing Maximum Permitted Levels began in 2005 with recommendations made by the German Federal Institute for Risk Assessment (BfR), the first organization to carry out this task. It should also be noted that not only will BfR be instrumental in providing “scientific” information to Codex, but that Dr. Rolf Grossklaus is BfR’s Director. This is the same Dr. Grossklaus that is the chairman of the Codex Committee on Nutrition and Foods for Special Dietary Uses and has become somewhat famous in the health freedom community for his tyrannical methods of conducting meetings,[9] as well as for making the claim that nutrition is only for maintaining health, not for the prevention or treatment of diseases.[10]
Indeed, Dr. Grossklaus was one of the leading scientists of the team that conducted the studies used in BfR's standings.[11] This is particularly concerning in light of the context of the CCNFSDU as Dr. Grossklaus is the man responsible for guiding the Commissions’ position on the safety of these substances. In this instance, the Chairman of the Codex committee requesting an assessment on nutrients is also the Director of the company conducting the assessment, as well as one of the leading scientists in the assessment itself. True science would never allow someone with such a blatant conflict of interest to take part in these studies. This, however, is business as usual with Codex.
But the clearly unscientific manner in which risk assessment is conducted apparently knows no bounds. Dr. Rima Laibow comments on this obvious conflict of interest further by saying:
Dr. Grossklaus uses his position to bludgeon through his own personal agenda and that of the European Union (EU) representative to Codex and CCNFSDU, Mr. Basil Mathioudakis. The two of them confer regularly as if there were no other members present and whatever the antinutrient Dr. Grossklaus and Mr. Mathioudakis agree upon is the 'outcome' of the deliberations. [12]Dr. Laibow’s assessment is a fairly accurate one. The methods by which Codex reaches its “consensus” are dubious to say the least. In fact, the “consensus” as declared by the CCNFSDU bears little resemblance to any other real consensus being reached on any other board. Scott Tips, who has regularly attended Codex meetings as an observer, elaborates further:
The Chairman was a German, Dr. Rolf Grossklaus, who ran the Codex meetings in an innovative (to me at least) way. After much discussion on a topic, and especially after the German government delegate did not seem to have anything more to say, the chairman would somehow psychically determine that a “consensus” had been reached or not reached by the delegates and the group would move on to the next topic of discussion. I never once saw a vote taken or even the slightest hint of a show of hands; the outcome was all calculated in Dr. Grossklaus’ marvelous brain as he scanned the room and remembered how many had spoken for or against each proposal. Of course, the squeaky wheels counted the most; the silent ones not at all. We Americans, who suffer from this obsessive notion that votes must actually be counted before deciding upon an outcome, might learn much from this economical and quick means of “voting.” In fact, stupid me, why even vote when the chairman could just decide for all of us?[13]Anyone who has attended these meetings with the expectation of observing some form of democratic input by anyone except the chairman or the EU must have been seriously disappointed. Indeed, this has been the impression of virtually every health freedom advocate that has ever attended these meetings.
Notes:
[1] Laibow, Rima. “’Nutraceuticide’ and Codex Alimentarius.” Alternative and Complementary Therapies, October 2005. P. 227
[2]Codex Committee On Nutrition and Foods For Special Dietary Uses. https://www.ccnfsdu.de/index.
[3] Ibid.
[4] Ibid.
[5] Laibow, Rima. “’Nutraceuticide’ and Codex Alimentarius.” Alternative and Complementary Therapies, October 2005.
[6] “Guidelines for Vitamin and Mineral Food Supplements.” Codexalimentarius.net www.codexalimentarius.net/
[7] Laibow, Rima. “’Nutraceuticide’ and Codex Alimentarius.” Alternative and Complementary Therapies, October 2005.
[8] Taylor, Paul Anthony. “Nutrient Risk Assessment: What You’re Not Being Told.” http://www4.dr-rath-
[9] Tips, Scott C. “Breathe Easier – Codex Adjourns.” Codex Alimentarius: Global Food Imperialism.” Ed. Scott C. Tips. Foundation for Health Research, 2007.
[10] Walter, Suzan. “Important News from Bonn.” Codex Alimentarius: Global Food Imperialism. Ed. Scott C. Tips. FHR. 2007. P.88.
[11] Taylor, Paul Anthony. “Nutrient Risk Assessment: What You’re Not Being Told.” http://www4.dr-rath-
[12] Laibow, Rima. “’Nutraceuticide’ and Codex Alimentarius.” Alternative and Complementary Therapies, October 2005.
[13] Tips, Scott C. “Breathe Easier – Codex Adjourns.” Codex Alimentarius: Global Food Imperialism.” Ed. Scott C. Tips. Foundation for Health Research, 2007.
Brandon Turbeville is an author out of Mullins, South Carolina. He has a Bachelor’s Degree from Francis Marion University where he earned the Pee Dee Electric Scholar’s Award as an undergraduate. He has had numerous articles published dealing with a wide variety of subjects including health, economics, and civil liberties. He also the author of Codex Alimentarius - The End of Health Freedom
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