American Holistic Health Association (AHHA) - Guidelines Preamble Concern
Guidelines
Preamble Concern


PREAMBLE
Most people who have access to a balanced diet can usually obtain all the nutrients they require from their normal diet. Because foods contain many substances that promote health, people should therefore by encouraged to select a balanced diet from food before considering any vitamin and mineral supplement. In cases where the intake from the diet is insufficient or where consumers consider their diet requires supplementation, vitamin and mineral food supplements serve to supplement the daily diet.

Throughout the years that the Guideline were developed by the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU), there were a number of attempts to liberalize the role of vitamins and minerals as defined in the Guideline Preamble. Each year the reason for disallowing these attempts was different.


1998
In 1998 the argument tried was that scientific data indicated that "diet may not be sufficient to meet the requirements for some nutrients of some population subgroups".


2002
In 2002 attempts were made to add mention of "prevention to reduce risk of disease." The EU led the objection based on it was not the committee's mandate "to consider the prevention, treatment or cure of diseases."

In Report From The Eastern Front: Author finds much to mistrust at recent Codex session in Berlin Scott Tips of National Health Federation reports on an attempt by Antoinette Booyzen of South Africa, "Mrs. Booyzen then proposed a new preamble to the Codex standards that recognized dietary supplements as important in preventing and reducing the risk of disease. All other delegations, such as Denmark, our old 'favorite' Norway, and Brazil, who spoke denigrated this position. Germany even called South Africa's proposed change procedurally incorrect because it had not been submitted in writing first. Because the chairman, who is German, always defers to the German delegate's stated position (I have never seen him act contrary to any position stated by the German delegate), the proposed South African change to the preamble was promptly deleted from the overhead screen used to show Codex language changes. Although I repeatedly requested recognition by the chairman to speak out in support of South Africa's proposed new preamble, the chairman flatly refused to call on me and I had to suffer the other delegations' ignorant remarks in silence."


In AHHA Attends Berlin Codex Session What did we learn? Suzan Walter reported, "The lead delegate from South Africa read a statement reminding the assembly of the scientific research supporting the value of vitamin and mineral supplements, including research quoted from a recent Journal of the American Medical Association article that recommends that adults take a multi-vitamin daily. There was actually applause from the assembly after her statement."

"Somehow the discussion became about supplements as defined by the Guidelines are not to be used to treat disease. Comments were cut off on a procedural technicality that South Africa had not included this in their published Comments. The Chair did agree to include the suggested new Preamble in the final Committee report."


2003
In 2003 the attempt to mention prevention was declined based on the position that the Codex General Guidelines on Claims prohibited this.

Codex 2003 - The EU tightens its grip by Paul Anthony Taylor includes a section on the discussion during the CCNFSDU session regarding attempts to revise the Preamble of the Guidelines. He reports, "The debate then passed quickly on to the text of the preamble. South Africa read out their proposed alterations, which included wording to the effect that people should 'be encouraged to select a healthy diet and supplement this diet with those nutrients for which the intake from the diet is insufficient to meet the requirements necessary for the prevention of chronic diseases and/or for the promotion of health beyond the demands of preventing micronutrient deficiencies.' The National Health Federation supported this, saying that this text merely states what we know to be true."

"The EC Observer however said that food and the prevention of diseases do not go together. He was supported by the Chairman in this, who said that drugs are to mitigate and prevent diseases, and that the role of food supplements is to support the diet."

"CRN talked about the classic nutritional diseases, the nutrient responsive diseases, and nutrients used as drugs, and said that this sort of categorisation should be the way forward. The EC Observer, however, said that health claims for vitamin and mineral supplements should be prohibited. The Chairman pointed out that the situation in the United States was different, and that the Codex Committee has a certain conflict regarding this issue. Medical supervision is important in this field, he said, and we should not talk about the prevention of diseases. The National Health Federation refuted the Chairman's statement however."

"Tunisia said that most people who have access to a balanced diet get sufficient nutrients, and that people should be encouraged to aim for a balanced diet. The Chairman then intervened in the discussion, saying that he wanted to stick to the preamble as it is, as the Codex Committee had been discussing this issue for years. Yet again then, rather than acting as a moderator the Chairman was playing the role of judge, and the discussions moved, or rather, were forced, onto the next paragraph of the Guidelines."

Interestingly however, the Draft Report described this intervention as follows:

After some discussion, the Committee agreed to retain the current text as it resulted from considerable discussion and consensus at the last session.


In Truman Tuck's report Grossklaus and Mathioudakis: Nutrition not relevant to Health he reports, "As I reported on 6 November, a very interesting proposal made by South Africa was, to officially acknowledge the importance of supplements to the prevention of degenerative diseases. What a pity that this was unceremoniously squashed by the German Chairman of the Committee Rolf Grossklaus and the 'Observer' at Codex for the EU Commission, Basil Mathioudakis."

"We now have an excellent report by Paul Taylor, who attended the discussions. Reading Paul's report, you will find out who are the people in control of the discussion that is supposed to be shaping laws we may have to follow in the future if we wish to continue to take nutritional supplements: One of them is Rolf Grossklaus, Chairman of the Committee, who often decided in a seemingly arbitrary fashion, what constituted a Committee 'consensus' and what didn't. The other major player is Basil Mathioudakis, the EU 'Observer', representing a solid block of nations whose officials attend the meetings but have practically lost any possibility of independent action."

"You will also find out that for these two officials, nutrition has "nothing to do with prevention" and that prevention "is the province of medicine". Let us stop and think for a moment: International legislation, which will deeply affect our health choices, not to speak of the laws and health expenditures of a multitude of countries, is being formed by an obscure Committee of government bueraucrats, which in turn appears to be controlled or "steered" by a very small number of individuals who think that health and nutrition are complete strangers!"

"Considering the view that "nutrition has nothing to do with preventing illness", is it any wonder that health expenditures in most countries are on the rise, while health of the population seems to be at an all-time low?"


In her report Important News from Bonn Suzan Walter, president of the American Holistic Health Association states, "Next, South Africa suggested revised wording for the Preamble to add mention of the role of vitamins and minerals in the prevention of chronic diseases. Since the Food and Agricultural Organization of the United Nation's World Health Organization (FAO/WHO) publication, "Diet, Nutrition and the Prevention of Chronic Diseases," was being distributed at the CCNFSDU session, it was assumed this premise would be an easy sell. The National Health Federation (NHF) spoke in support of the South African suggestion. When, the EC delegate took the floor, he insisted that food and prevention did not go together. The chair commented that medicines are for prevention and treatment of diseases, whereas food supplements are to maintain health. There was continued discussion, with the key point being that Codex regulations prohibited claims that food prevents disease. The chair declared that the Preamble would not be revised.


2004
In 2004 the Chair would not allow the matter to be addressed.


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