Dr Sarah Myhill and Food Supplement Regulations

December 31, 2011 at 1:56 pm (Nutritionism, Supplements) (Dr Sarah Myhill, Food Supplements)

The webpages here and here marketed supplements and contained statements implying that a balanced and varied diet cannot provide appropriate quantities of nutrients in general. For example: “I believe that if you wish to stay healthy, or recover from almost any illness, then taking nutritional supplements is essential. My reasons are given in Nutritional supplements – why we all need them.”

This is contrary to Article 7 of Directive 2002/46/EC, implemented in this country by Provision 6 (4) of the Food Supplements (England) Regulations 2003 and in Wales by Provision 6 (4) of the Food Supplements (Wales) Regulations 2003:

Article 7 – “The labelling, presentation and advertising of food supplements shall not include any mention stating or implying that a balanced and varied diet cannot provide appropriate quantities of nutrients in general.”

Provision 6 (4) – “No person shall sell any food supplement which is ready for delivery to the ultimate consumer or to a catering establishment if the labelling, presentation or advertising of which includes any mention, express or implied, that a balanced and varied diet cannot provide appropriate quantities of vitamins or minerals in general.”

I contacted Trading Standards in August and, in November, one of the pages was altered a little: Nutritional supplements…

Dr Myhill has removed from this page the instructions for how to buy her supplements, and has also (mostly) removed the tradenames of various products she has been promoting. There is still a contact email for purchasing food supplements on the contact us page as well as references on the nutritional supplements page to Biocare multivitamins and Myhill’s Magic Minerals (now referred to as Mineral Mix, or MM). Here are some of the deleted statements:

I am also sourcing lithium – in doses of 1mg per day this is protective against dementia; lithium to treat mental disorders is used in hundreds of milligrams.

The above nutritional regime is designed for my patients but can, of course, be implemented by anyone who can obtain BioCare products and my mineral mixes.

Please, request a Nutritional Supplements Price List from my office.

It looks as if Dr Myhill has decided to remove references to brand names and the sale of supplements from her page in order to allow her to voice her unsubstantiated personal opinions on ‘the Western diet’ while staying just the right side of the law.

The most interesting element of this exercise for me is the discovery that Trading Standards do appear to be willing to enforce the requirements of food supplement regulations. Another point of interest is that Dr Myhill has added a section on compliance with the law. It’s almost as if Dr Myhill is annoyed at having to comply with the regulations on promotion of food supplements:

The law of the land is that nutritional supplements are not necessary for anyone eating a balanced diet. Of course this begs the question as to what is a balanced diet? By definition a balanced diet is one that supplies all the necessary macro and micronutrients in adequate amounts for optimum health. The problem is that Western diets do not deliver and so by definition are not balanced. Indeed during 30 years of nutritional practice I have yet to see normal levels of micronutrients in a healthy person eating a Western diet! That is why I came to the view that the above approach is necessary.

Dr Myhill believes that we’re unable to obtain sufficient quantities of nutrients from our diet, that RDA levels are too low (Myhill states that “RDA amounts were set down in 1941 and are now outdated”, which is misleading as RDA amounts have been reviewed and revised several times since 1941), and that everyone needs to take vitamin pills.

With regard to the setting of RDA levels:

The term [RDA] recognises that particular groups of individuals (E.g. infants and those over 60) have different needs and for each group, the intention was to be sufficiently generous to encompass the presumed (but unmeasured) variability in requirement among people. This meant that the value was usually set deliberately high. [Derek Shrimpton]

Those setting RDAs have recognised that we are all individuals, with nutrient requirements that vary. They set the RDAs deliberately high in order to compensate for this variation in the amounts of nutrients required. Given that RDAs are usually set deliberately high, it’s actually more likely that they are over and above our needs rather than being ‘sub-optimum’. But that won’t be enough to reassure some people – they will still worry about the low levels of vitamins they assume they are consuming. More on that in a moment.

With regard to our diets lacking micronutrients, there is this paper, which notes that “Using data from 1688 British children aged 4–18 years who completed 7 d weighed dietary records in 1997, micronutrient intakes were examined across quintiles of added sugars. After excluding low energy reporters, mean dietary intakes of most nutrients exceeded the reference nutrient intake, except for zinc.”

And what happens if people follow Dr Myhill’s advice that everyone needs to take supplements? This paper reports that “Long-term supplementation with antioxidant vitamins and minerals had no beneficial effect on HRQoL [Health-Related Quality of Life] in this trial. This is contrary to conventional beliefs and claims that such an effect exists.” The Daily Mail reported on this trial, as can be seen on the Daily Veil website.

Experts said the study – one of the most extensive carried out into vitamin pills – suggested that millions of consumers may be wasting their money on supplements.

Many users fall into the category of the ‘worried well’ – healthy adults who believe the pills will insure them against deadly illnesses – according to Catherine Collins, chief dietician at St George’s Hospital in London. She said: ‘It’s the worried well who are taking these pills to try and protect themselves against Alzheimer’s disease, heart attacks and strokes. ‘But they are wasting their money. This was a large study following people up for a long period of time assessing everything from their mobility and blood pressure to whether they were happy or felt pain.’

There are some specific cases where supplementation is advised (for example, Folic Acid is recommended from the time you stop using contraception until the 12th week of pregnancy) but blanket recommendations to supplement vitamins and minerals are unwarranted.