Your Commentary: Kemper & Benoir/Federal Office, Dacher/"Integral Education", ND/AMA SOPP, Levin/Product Quality

Kemper and Benoir: Issues with a Federal Office for Integrated Health Care

Kathi Kemper, MD: wellness office needed

Kathi Kemper, MD, is an author and integrative medicine leader at Wake Forest University volunteered a response on

"We need a federal office on wellness! Not just integrated health care, which usually translates into 'sickness and injury management to make money for large corporations such as big pharma and insurance and hospitals.' I'm not sure I want dietary supplements and others just getting into this large feeding trough.

"I feel we need a revolution to change the focus and to reward healthy living. This includes advocacy for sustainable environment, sensible transportation, organic farming, less land rape, etc. Not just tracking a few CAM therapies onto the already broken 'system.'"

"In an ideal world, this is a good idea. I would opposed this very strongly, however, in the world as it is. CAM interests do not have the time or financial resources to monitor or lobby such a Federal office - in comparison to Pharma, AMA and other interests that have substantial resources. The odds are that this would end up a regulating body that is restrictive rather than facilitative."

Dacher: Distinguishing Between "Integral Education" and Mind-Body Strategies

Dacher: lineage of "integral education"

Author Elliott Dacher, MD, wrote on the reference to "integral education" in Peter's Amato's work as described in

"The Inner Harmony program in schools is quite similar to various other programs  based on introducing Jon Kabat-Zinn's Mindfulness Based material. These are very useful programs yet

(founder Peter Amato) has distinguished his with the term "integral education."

"I feel it is important to honor the lineage of such terms and to hold them with intent, clarity, and dignity. Aurobindo first wrote about "Integral Education" and his works are available and then (Ken) Wilber built on it. The essence of Aurobindo's writings and the school he developed around it was to develop the soul and spirit of the child rather than focus  as we do, solely on mental, rational-linear development. The mind or mental learning is by nature dualistic and cognitive (certainly of worldly value,) but unity, wholeness, and the qualities of wisdom, and uncontaminated love and compassion can only emerge from the higher mental capacities of spirit and soul as these are unitary in nature. So Aurobindo focused on teaching children to trust their innerness, develop it, and use it as a source of harmony and balance in life. Thus an "integral education.

"This is much different than using meditative techniques to enhance attention, sensitivity, learning  skills and so on ... a valuable and necessary process, but the aim is not the same as an integral approach to the human life.

"My sense is that the term integral will be increasingly used and abused, but it is helpful for all of us to consider it carefully as our lives and possibilities hang in the correct understanding and intent."

"I think that the era of integration is ending. The MDs are now unmasked. I think we (in naturopathic medicine) have gained a lot in the past 20 years. That's why the MDs want to take our success for them. Again, the cold war has become the hot war.

"Our experience is to not trust them anymore. We (in naturopathic medicine) should focus on gaining respect for ourselves like the chiropractors did."

"Dr. Liva reminds us that "you get what you pay for".

"A health products industry has a moral imperative to deliver nutritional supplements that are authentic, potent and pure. Yet, as evidenced by Dr. Liva's examples, and by the hundreds of test results published at www.consumerlabs.com and elsewhere teaches us, there are, literally, scores of subpotent, counterfeit and adulterated products in use today. The use of these poor quality products also creates collateral damage: they confound clinical research (did the patient not respond to black cohosh, or was the product an entirely different genus:species?). Everyone loses.

Levin: quality lessons in the natural products trade

"The QA self-audit is an excellent idea (the results from which should provide very interesting reading!). Though claims such as 'GMP-compliant', 'GMP-certified', 'USP certified' and 'NSF-certified' all sound very reassuring, and although they are certainly steps in the right direction, practitioners are best advised to self-prescribe a healthy dose of skepticism. Why? Though the product certification bodies (USP and NSF) do an excellent job on standards regarding identity and potency, both fall short on purity issues. Example: NSF has no requirement for solvent residue testing (they're 'working on it') . Some USP monographs have very generous specifications on solvents, pesticides and heavy metals; so generous, in fact, that it is possible to have a USP-certified (or NSF-certified) product that contain enough contaminants as to require consumer warnings under California law (Prop 65) for carcinogens and reproductive toxins.

"Teaching Example: In 2004, Federal Marshals seized American Ginseng that was contaminated with the illegal pesticide, PCNB. At least one 'NNFA-GMP certified' company (a very fine, well-intentioned firm) recalled contaminated product from the market - they apparently weren't testing their raw materials for that particular contaminant. Despite the federal action, the first published NSF-USP standard that requires Ginseng to be tested for PCNB was not adopted until mid-2005. Shouldn't we expect the products we use to have maximum freedom from dangerous contaminants? Product purity begins with raw materials, which is exactly where (in my view) greater focus and investment is required.

"Globalization, and a combination of poor agricultural practices and lack environmental controls in China have created the 'perfect storm'. Where did the PCNB come from? Work done by the World Bank teaches us that water quality is poor (in August, 2006, Coke and Pepsi products manufactured in India and China contained 24 times the allowable limit for pesticides under proposed Indian law), farmers irrigate crops with industrial wastewater, overuse agrochemicals, and China now leads the world in hepatic cancer mortality (for additional information, refer to Dr. Jeremy Appleton's article published in the second issue of Integrative Medicine). With that as a backdrop, there is a compelling reason for us to demand comprehensive purity testing of all products we use to promote health, especially those we import!

"What about certificates of analysis that accompany every shipment of raw material? As one wise scientist told me (and years of experience has proven) 'paper never refuses ink'.

"Will FDA published GMPs fix this problem? No. They won't. The GMPs (like JCAHO) require that certain processes be in place, but do NOT prescribe the details; defining the quality standards are, for the most part, left entirely to the company to define.

"How pure is pure enough? Dr. Liva speaks to genus-species identity testing for all botanicals, comprehensive solvent residue testing, extensive herbicide, fungicide and pesticide testing....all of which I agree should be done, but few (in my experience) are doing to that level. As for 'GMP-certification' claims, upon my request for evidence of 'certification', I was presented with a document that certified the vendors' manufacturing plant for 'Granules (including) Dry Suspension (Including Cephalosporins)' in compliance with the requirements of Chinese Good Manufacturing Practices for Pharmaceutical Products.' Hmm. GMP-certified. What does that really mean? Are my supplements being produced in a Chinese cephalosporin plant?

"Speaking of drugs, how did the chloramphenicol get into Chinese honey-based products a few years ago? (Answer: they doused the hives with chloramphenicol to increase production. The EU, UK, Canada, and US all took enforcement action).

"Caveat Emptor. And, lest you think that the natural products industry is doing a poorer job on quality than big pharma, you'll be interested to know that consumerlabs.com reportedly found 3 mcg of lead (above the California Prop 65 threshold of 0.5 mcg/day) in tablets of a leading multiple vitamin product; for more info, visit www.consumerlabs.com. For enforcement actions taken against foods, supplements and drugs, visit www.fda.gov)."