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Newsletter 02 2006.pdf - Sight and Life

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SIGHT AND LIFE 20<br />

NEWSLETTER 2/2006<br />

enzymes (the so-called “knock<br />

out” mouse) to draw inferences<br />

about pathways in carotene<br />

metabolism. Geneticist created<br />

knock-out animals, deprived of<br />

or suppressed regarding one or<br />

another receptor. These proved<br />

to be strong investigative tools<br />

to use in pursuing the role of<br />

transporters in carotene uptake.<br />

In concluding his talk, Dr Harrison<br />

summarized a series of Beltsville<br />

laboratory experiments using<br />

receptor inhibitors, knock-out<br />

mice <strong>and</strong> their combination, to<br />

illustrate a partial dependency of<br />

carotene uptake on this class of<br />

membrane-associated enzyme<br />

as the basis for facilitated cellular<br />

uptake of carotenoids in the<br />

intestine.<br />

Dr Kathleen C Ellwood, of the<br />

Center for Food Safety <strong>and</strong> Applied<br />

Nutrition (CFSAN) of the<br />

Food <strong>and</strong> Drug Administration<br />

(FDA) of the United States presented<br />

the topical theme Reviewing<br />

the Scientific Evidence for<br />

Health Claims. Dr. Ellwood is assigned<br />

to the Division of Nutrition<br />

Programs <strong>and</strong> Labeling, Office<br />

of Nutritional Products Labeling<br />

<strong>and</strong> Dietary Supplements of the<br />

CFSAN. She provided a lucid<br />

exposition of the United States<br />

government’s oversight <strong>and</strong> regulation<br />

in the food-labeling area,<br />

<strong>and</strong> participated in a lively <strong>and</strong><br />

interactive question <strong>and</strong> answer<br />

period thereafter. Need for labeling<br />

rules came about with the<br />

expansion of knowledge about<br />

bioactive substances in foods<br />

(of which the various carotenoids<br />

are examples). There came an<br />

effort by manufacturers of foods<br />

<strong>and</strong> supplements in the United<br />

States to transform findings into<br />

claims of beneficial effects. This<br />

led producers <strong>and</strong> marketers to<br />

seek to make claims about the<br />

benefits of consumption of the<br />

substances, the food containing<br />

the substances or both. To the<br />

extent that foods <strong>and</strong> substances<br />

are offered as remedies <strong>and</strong><br />

therapies, a specific regulatory<br />

Kathleen C Ellwood<br />

h<strong>and</strong>ling comes into play. Dr.<br />

Ellwood correctly presented this<br />

as a case example of the merger<br />

of science with policy.<br />

Claim statements for a product<br />

are a form of “speech”; within<br />

the United States of America,<br />

freedom of speech is protected<br />

by the First Amendment to the<br />

Constitution. Provisions for making<br />

claims for health regarding a<br />

retail product are now covered by<br />

legislation (statutes) <strong>and</strong> the judicial<br />

precedents (case law). The<br />

FDA considered disease therapy<br />

claims for foods in the 1970s <strong>and</strong><br />

1980s, <strong>and</strong> concluded that food<br />

must be treated by the same<br />

st<strong>and</strong>ards as any drug.<br />

Since that era, however, emerging<br />

scientific discovery has shown a<br />

series of more subtle diet-health<br />

relationships including protection<br />

<strong>and</strong> preservation of wellbeing<br />

<strong>and</strong> function. U.S. consumers<br />

were interested in seeking the<br />

potential benefits from dietary<br />

factors, <strong>and</strong> there was marketing<br />

pressure to deliver what the<br />

consumer dem<strong>and</strong>ed. This led to<br />

the passage in 1990 of the Nutrition<br />

Labeling <strong>and</strong> Educational<br />

Act, which governs the nature of<br />

claims that could be attached to<br />

edible products. It was not about<br />

treating established disease, i.e.<br />

the drug action, but rather about<br />

“Health Claims”. The act regulated<br />

claims of causal relationships<br />

between a food substance<br />

<strong>and</strong> a disease or health-related<br />

condition in the general US<br />

population or sub-population, in<br />

which consumption could reduce<br />

their risk. For the Health Claim to<br />

be approved the st<strong>and</strong>ard was<br />

“significant scientific agreement”,<br />

that is a strong consensus of a<br />

causal relationship.<br />

The speaker recounted how<br />

manufacturers felt constrained<br />

by having to get over such a high<br />

bar; they brought suits in court<br />

claiming that the Act infringed<br />

upon the First Amendment guarantee<br />

of freedom of speech. This<br />

has led, since 1999, to a secondary<br />

level of regulation for labeling,<br />

the so-called Qualified Health<br />

Claim (QHC). These claims include<br />

qualifying language in order<br />

to prevent the consumer from being<br />

misled. QHCs are applied for<br />

relationships such as that relating<br />

lycopene or lycopene-containing<br />

foods to reduced risk of prostate<br />

cancer <strong>and</strong> similar assertions.<br />

The process of evaluation by the<br />

FDA for a QHC has a defined<br />

set of steps. The first is literature<br />

review <strong>and</strong> selection. Animal<br />

studies are not relevant. Insofar<br />

as observational studies can<br />

indicate association, but not causality,<br />

the most relevant literature<br />

is considered to be that from intervention<br />

trials. The interventions<br />

can have outcomes of reduced<br />

incidence of disease/condition<br />

or favorable modification of a<br />

validated modifiable risk factor<br />

related to ill health.<br />

San Francisco’s famous cable<br />

cars.

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