Collin's Comment on Fry's "Swift" Editorial
Jonathan Collin, MD
feel honored to be compared, if only derisively, to the English
author Swift. And I do regret that I don't have wit. The points
made in Mr. Fry's commentary are certainly meritorious. However,
the concern in my editorial remains whether major drug companies
manufacture key ingredients used in the production of "natural"
vitamin supplements. It appears that in many cases drug companies
are the key manufacturer. No matter what buffering process is employed,
ascorbic acid (Vitamin C) is being produced by the drug company.
Why then is ascorbic acid available in so many different forms at
widely varying prices?
Fry reports as an "insider" that the difference between wholesale
pricing and retail pricing is based on an industry based formula
of 70-100% markup, or the wholesale is 50-60% of retail. He also
states that some companies attempt to provide better pricing by
depending on high volumes of sales so that the retail markup is
only 30 to 50%. These facts are important but my editorial was concerned
not with retail pricing, but how a company determines its wholesale
price. How can one product of vitamin C have a wholesale price of
$3.00, another $5.00, another $7.00 and another of $1.00? While
there may be some differential on price based on quality and volume,
some manufacturers are clearly charging far more than others for
the same basic product. On the other hand, a few manufacturers are
claiming on their labels to have identical product, but actually
have adulterated product which clearly enables them to sell for
much less than a standard price.
1984 one scientist reviewed Vitamin E available in the marketplace
at the health food store or pharmacy. This evaluation of Vitamin
E did not concern itself with whether the Vitamin E was dl-alpha
tocopherol (synthetic) or d-alpha tocopherol (natural). Instead,
the survey studied only the content of tocopherol and found that
the content of Vitamin E in the different products all claiming
to have 400 IU of Vitamin E, varied from having 400 IU to not having
any Vitamin E in the product at all, being only pure soy
oil. The FDA may have had power to remove the mislabeled products
but did not, in fact, remove any of these supplements. In this case,
adulteration of supplements was found in the marketplace and not
policed effectively either by regulatory agency, the vitamin industry,
or through consumer groups. Hence these manufacturers were able
to sell a very inexpensive product because the product did not contain
the vitamin content stipulated on the label. (This was reported
in the Dec/Jan 1984 issue of the Townsend Letter for Doctors.)
we have not had sufficient surveys of supplement products made and
verified by industry overseers, a number of consumer publications,
especially Consumer Reports, have assayed vitamin,
mineral and herbal content of supplements available in the marketplace.
Unfortunately the results of such surveys have not been good. Like
the Vitamin E study cited above, widely varying contents of the
nutritional substance specified on the label were determined to
be present. Generally speaking, the largest, most commercially successful
companies most often had the products that reliably contained the
labeled nutrient. But not always.
expected, companies that were not widely known were most frequently
guilty of mislabeling the contents of their supplement. As these
products were found in the marketplace, there is no effective mechanism
in place that polices such mislabeling. It is not at all unusual
for consumers and practitioners to be mistrustful of the supplement
industry because of these widespread abuses. The free opportunities
now available to manufacture nutritional supplements offers widespread
distribution of many mislabeled products by companies led only by
businessmen, many of whom are interested in nothing except making
profit. While several dozen product manufacturers existed in the
1980's, the number of manufacturers has multiplied 100-fold. Although
the largest of these companies can be reliably trusted, the vast
majority of the other manufacturers cannot. It is this latter group
that needs policing. Given the fact that the FDA and FTC and state
pharmacy and manufacturing boards are not regulating these mom-and-pop
operations, who will do the regulating? Should it be okay for a
7th grade student who has $1M available from his parents' stock
options to open his own vitamin company? At this time a 7th grader
could operate a vitamin company and there would be no effective
policing of his products by anyone.
have reached a new stage in supplement manufacturing in the year
2000 which has opened the door for a lot of flim-flam product distribution.
It is necessary for the industry to regulate spurious and adulterated
products by pooling resources to begin conducting a "good-housekeeping"
assessment of food supplements and labeling. An independent laboratory
must conduct the analysis on all basic vitamins, minerals, herbals,
and nutraceuticals, and be sufficiently funded to conduct and publish
analyses. Until such a testing laboratory is available for analyzing
the content of supplements in the marketplace, all supplement products
should be held in question unless the manufacturer conducts assays
carried out by independent research laboratories. The assays should
be available upon request to practitioners and public. Without the
lab analyses made public, it should be assumed that the product
is not reliable and should not be purchased.
challenge the supplement industry to fund and support an independent
testing laboratory for evaluation of each and every supplement available
in the marketplace.
Fry's editorial: Reading the Townsend Letter editorial
"Vitamins Inc. Cartel" was like reading Jonathan Swift's "modest
proposal" to eat our young as a means of resolving human population
pressures. The editorial, however, lacked Swift's irony and wit,
and certainly didn't read like satire. In
lieu of a trip to Lilliput, the Townsend editor might consider
traveling to Germany to observe the kind of regulatory environment
he seems to invite . . .
Collin's original editorial -- Vitamin Inc. Cartel: In the last
ten days of May the US Justice Department disclosed and fined a
European vitamin cartel . . .