(A presentation by Andrew W. Saul to the Government of Canada, House of Commons Standing Committee on Health, specifically in reference to C-420, on May 12, 2005, Ottawa, Canada.)
Honorable Ladies and Gentlemen:

Natural health products, such as amino acids, herbs, vitamins and other nutritional supplements, have an extraordinarily safe usage history. In the USA, close to half of the population takes herbal or nutritional supplements every day. That is over 145,000,000 individual doses daily, for a total of
over 53 billion doses annually.

The most elementary of forensic arguments is, where are the bodies?

To try to answer this question, we may turn to the 2003 Annual Report of the American Association of Poison Control Centers Toxic Exposures Surveillance System, published in the American Journal of Emergency Medicine, Vol. 22, No. 5, September 2004.


This report states that there have been four deaths attributed to vitamin/mineral supplements in the year 2003. Two of those deaths were due to iron poisoning. That means there have been two deaths allegedly caused by vitamins, out of over 53 billion doses. That is a product safety record without equal.

Pharmaceutical drugs, on the other hand, caused over 2,000 poison control-reported deaths, including:

Antibiotics: 13 deaths

Antidepressants: 274 deaths

Antihistamines: 64 deaths

Cardiovascular drugs: 162 deaths

It would be incorrect to state that only prescription drugs kill people. In 2003, there were 59 deaths from aspirin alone. That is a death rate nearly thirty times higher than that of iron supplements. Furthermore, there were still more deaths from aspirin in combination with other products.

Fatalities are by no means limited to drug products. In the USA in the year 2003, there was a death from "Cream/lotion/makeup," a death from "Granular laundry detergent," one death from "Gun bluing," one death from plain soap, one death from baking soda, and one death from table salt.

Other deaths reported by the American Association of Poison Control Centers included:

aerosol air fresheners: 2 deaths

nailpolish remover: 2 deaths

perfume/cologne/aftershave: 2 deaths

charcoal: 3 deaths

dishwashing detergent: 3 deaths

(and interestingly, weapons of mass destruction: 0 deaths)

In America in 2003, there were 28 deaths from heroin, and yet acetaminophen ("Tylenol") alone killed 147. Though acetaminophen killed over five times as many, few would say that we should make this generally-regarded-as-safe, over-the-counter pain reliever require prescription. Even caffeine killed two people in 2003, a number equal to the two fatalities attributed to non-iron vitamin/mineral supplements. Tea, coffee and cola soft drinks are not sold with restriction, prescription, or in childproof bottles, and rather few would maintain that they need to be.


Nutritional supplements are exceptionally safe. In 2003, there were no deaths from multiple vitamins without iron. There were no deaths from amino acids. There were no deaths from B-complex vitamin supplements. There were no deaths from niacin. There were no deaths from vitamin A. There were no deaths from vitamin D. There were no deaths from vitamin E.

There was, supposedly, one alleged death from C and one alleged death from B-6.

The accuracy of such attribution is questionable, as water-soluble vitamins such as B-6 (pyridoxine) and vitamin C (ascorbate) have excellent safety records stretching back for many decades. "Vitamin problem" allegations are routinely overstated and unconfirmed. The latest (2003) Toxic Exposures Surveillance System report indicates that reported deaths are "probably or undoubtedly related to the exposure," a clear admission of uncertainty in the reporting. (p 340)

Even if true, such events are aberrations. For example, In 1998, the American Association of Poison Control Centers' Toxic Exposure Surveillance System reported no fatalities from either vitamin C or from B-6. In fact, that year there were no vitamin fatalities whatsoever. For decades I have asked my readers, colleagues, and students to provide me with any and all scientific evidence of a confirmed death from either of these two vitamins, or from any other vitamin. I have seen none to date.


The 2003 Report of the American Association of Poison Control Centers Toxic Exposures Surveillance System (
http://www.aapcc.org/Annual%20Reports/03report/Annual%20Report%202003.pdf) indicates a total of 13 deaths attributed to herbal preparations. Three of these are from ephedra, two from yohimbe, and two from ma-huang. I have worked extensively in the alternative health field for nearly 30 years, and I have known of virtually no one who has taken ephedra, yohimbe, or ma-huang, and certainly not in the deliberately abusive high quantities that it takes to kill someone. Nevertheless, accepting all seven deaths attributed to these products, we still find that there were 30 times as many deaths from aspirin and acetaminophen.

Only three deaths are attributable to other "single ingredient botanicals," and oddly enough, their identity remains unnamed in the Toxic Exposures report.

Millions of persons take herbal remedies, and have done so for generations. Indigenous and Westernized peoples alike have found them to be safe and effective, and the 2003 Report of the American Association of Poison Control Centers Toxic Exposures Surveillance System confirms this (p 388-389). There have been no deaths at all from "cultural medicines," including ayurvedic,
Asian, Hispanic, and in fact, from all others.

Additionally, we find:

Blue cohosh: 0 deaths

Ginko biloba: 0 deaths

Echinacea: 0 deaths

Ginseng: 0 deaths

Kava kava: 0 deaths

St John's wort: 0 deaths

Valerian: 0 deaths

Furthermore, there have been no deaths from phytoestrogens, glandulars, blue-green algae, or homeopathic remedies.


Of the eight deaths in the category, five of them are from non-supplement sources rightly termed "electrolytes": two from sodium and three from potassium (p 389). Two deaths were allegedly due to iron overdose. Since 1986, there has been an average of two deaths per year "associated with" iron supplements. The sole remaining death was from calcium, a mineral that is employed medically for its antidote properties. In fact, in 2003, calcium was used as a lifesaving antidote in 5,228 cases (p 344). There is no evidence that the single listed calcium death was from a supplement, and the odds are overwhelming that it was not.


In 2003, poison control centers reported no deaths whatsoever from amino acids. This is in itself a strong safety statement.


Supplementation's harshest critics have traditionally railed against vitamins (especially in large doses) as being outright "dangerous" and at the very least "a waste of money." Yet nutritional supplements are very safe, and for much of the population, very necessary. . . To illustrate how extraordinarily important supplements are to persons with a questionable diet, consider this: Children who eat hot dogs once a week double their risk of a brain tumor. Kids eating more than twelve hot dogs a month (that's barely three hot dogs a week) have nearly ten times the risk of leukemia as children who ate none. (Peters JM, Preston-Martin S, London SJ, Bowman JD, Buckley JD, Thomas DC. Processed meats and risk of childhood leukemia. Cancer Causes Control. 1994 Mar; 5(2):195-202.)

However, hot-dog eating children taking supplemental vitamins were shown to have a reduced risk of cancer. (Sarasua S, Savitz DA. Cured and broiled meat consumption in relation to childhood cancer. Cancer Causes Control. 1994 Mar; 5(2):141-8.)

It is curious that, while theorizing many "potential" dangers of vitamins, the media often choose to ignore the very real cancer-prevention benefits of supplementation. . . Media supplement-scare-stories notwithstanding, taking supplements is not the problem; it is a solution. Malnutrition is the problem.

The number one side effect of vitamins is failure to take enough of them. Vitamins are extraordinarily safe substances. Drugs are not. There are over 106,000 deaths from pharmaceutical drugs each year in the USA, even when prescribed correctly and taken as prescribed. (Lucian Leape, Error in medicine. Journal of the American Medical Association, 1994, 272:23, p 1851. Also: Leape LL. Institute of Medicine medical error figures are not exaggerated. JAMA. 2000 Jul 5;284(1):95-7.)

Public supplementation should be encouraged, not discouraged. Supplements are a cost-effective means of preventing and ameliorating illness. Supplement safety is outstandingly high. Natural health products should be classified as foods, not drugs.


You can read the full text of Andrew Saul's Parliamentary presentation at


En francais: http://www.doctoryourself.com/testimonyfrancais.htm