Not All Changes Are Good

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May 21, 2014 by Dr. Sana Keller

FDAI realize that ‘legislative stuff’ can be boring to read about/learn about, but sometimes it’s just that important—this is one of those times. The FDA recently proposed an updated nutrition and supplement labeling format. Updating the format for the labels we see on food packaging and supplements is a good thing, especially since it hasn’t been done for 20 years. These proposed updates can be found in the 109 page FDA Proposed Rulemakinglabel

The rest of the story found in the many pages of this document include non-science-based changes for nutritional supplement Recommended Daily Intake (RDI’s) which are NOT supportive of good health. Below are a few of the many proposed changes (a full table of changes is at the end of this post):

  • Lowering the RDI for Vitamin B2 (riboflavin) even though it’s necessary for absorption of other nutrients and nearly impossible to overdose on.
  • RDI’s are proposed at lower levels for zinc, Vitamins B6 & B12 even though deficiencies in these are quite common.
  • Both biotin and chromium are necessary for blood sugar control, yet the proposal suggests lower RDI’s for both—even though Type II Diabetes and Metabolic Syndrome cases continue to rise.
  • Alpha-tocopherol is listed as the only biologically active form of Vitamin E, which is untrue. There are 8 different forms of active Vitamin E, including gamma- and delta-tocopherol which have both been shown to slow the growth of breast cancer.
  • The RDI for calcium has been increased by 30% even though excess calcium may lead to arterial calcification, especially if not balanced with Vitamin D, Magnesium & Vitamin K2).


For clarification, RDI’s are Recommended Daily Intakes of a nutrient for healthy people on a daily basis, developed by the Food and Nutrition Board at the Institute of Medicine. DV’s are Daily Values, established by the U.S. Food and Drug Administration FDA, and are used on food and dietary supplement labels. For each nutrient, there is one DV for all people ages 4 years and older. Therefore, DVs aren’t recommended intakes, but suggest how much of a nutrient a serving of the food or supplement provides in the context of a total daily diet.

I bring this to your attention to underline the message that we should not be relying on large government-run agencies for accurate and beneficial health information. Each of us are the ‘owners’ of our health and deserve access to nutritional supplements that are beneficial in maintaining our health—with EXTREMELY LOW risk or chance of side effects. Making changes to the Recommended Daily Intake (RDI) of vitamins and minerals without accurate scientific data is wrong—and could lead to even greater health challenges in the future if they are actually put into practice.

Below is one way that you can make your position on this issue known. I already have—it’s that important.


The FDA is accepting comments regarding these proposals from the public for a ninety-day period, which ends on June 2, 2014.  You can weigh in with your opinion, now by sending your comments electronically to the FDA at!submitComment;D=FDA-2012-N-1210-0002 or in writing to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5360 Fishers Lane, Rm. 1061, Rockville, Maryland 20852. Mention Docket No. FDA-2012-N-1210. Feel free to use, and embellish upon, the following wording below (from the GreenMedInfo site) to paste into your e-comment on the FDA website:

“On Docket No. FDA-2012-N-1210, I am adamantly opposed to your proposed reduction of vitamin-and-mineral Recommended Daily Intakes as shown in your Table 2, on page 11931.  At a time when toxin intake is increasing and nutrient intake is decreasing, Americans need more vitamins and minerals on a daily basis, not less. Your unsupported goal of harmonizing our food laws to Codex standards and guidelines has been specifically prohibited by Congress, and I demand that you obey the law and immediately withdraw Table 2 and all supporting paragraphs of your Proposed Rulemaking for revision in line with modern nutritional science, which shows that we need a higher daily intake of B and other vitamins as well as more magnesium and other minerals such as selenium.  Please act immediately to correct your serious errors.”

The FDA’s Table 2 referenced above (RDI=Recommended Daily Intake):

Nutrient Current RDIs Proposed RDIs
Biotin 300 micrograms 30 micrograms.
Choline 5501milligrams 550 milligrams.
Folate 400 micrograms 400 micrograms DFE.
Niacin 20 milligrams 16 milligrams NE.
Pantothenic acid 10 milligrams 5 milligrams.
Riboflavin 1.7 milligrams 1.3 milligrams.
Thiamin 1.5 milligrams 1.2 milligrams.
Vitamin A 5,000 International Units 900 micrograms RAE.
Vitamin B 6 2.0 milligrams 1.7 milligrams.
Vitamin B 12 6 micrograms 2.4 micrograms.
Vitamin C 60 milligrams 90 milligrams.
Vitamin D 400 International Units 20 micrograms.
Vitamin E 30 International Units 15 milligrams.
Vitamin K 80 micrograms 120 micrograms.
Calcium 1,000 milligrams 1,300 milligrams.
Chloride 3,400 milligrams 2,300 milligrams.
Chromium 120 micrograms 35 micrograms.
Copper 2.0 milligrams 0.9 milligrams.
Iodine 150 micrograms 150 micrograms.
Iron 18 milligrams 18 milligrams.
Magnesium 400 milligrams 420 milligrams.
Manganese 2.0 milligrams 2.3 milligrams.
Molybdenum 75 micrograms 45 micrograms.
Phosphorus 1,000 milligrams 1,250 milligrams.
Potassium2 3,500 milligrams 4,700 milligrams.
Selenium 70 micrograms 55 micrograms.
Zinc 15 milligrams 11 milligrams.

Thanks for keeping informed. Please add your questions and comments below.

Sana Keller, MS, RN, CNC, MH, HHP

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