Dr. Collin's Comment on Fry's "Swift" Editorial
by Jonathan Collin, MD

I 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?

Mr. 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.

Content varied

In 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.)

Although 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.

Guilty of mislabeling

As 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.

Independent laboratory testing

We 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.

We 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 . . .