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Dietary supplements, functional foods, probiotics, herbals, botanicals, nutra-centicals—is this food we're eating, or are we self-medicating? That is not only the question but also the conundrum. What are we buying, and why are we buying? We must have some idea because we're wiping the products off the shelves faster than they can be replaced. In 2004, dietary supplements were wisked off the shelves to the tune of $19.8 billion; herbals and botanicals, $4.2 billion; and functional foods, $22 billion. These $46 billion's worth is expected to become $50 billion by 2010. Those $46 billion came from some 50% of our citizens—teenagers, seniors, and dieters—both ill and healthy. Are we simply giving our money away, or is the public onto something—something that scientists and physicians have yet to grasp?

Does ginkgo biloba enhance memory, and does St. John's Wort ameliorate depression? Can shark cartilage prevent cancer, and can comfrey cure

Our Precarious Habitat. . . It's In Your Hands, Fourth Edition. By Melvin A. Benarde Copyright © 2007 John Wiley & Sons, Inc.

arthritis? Does garlic reduce serum cholesterol? How would we know? These are not idle questions. They require pursuit and responses. With some 30,000 products available, these are serious questions.

Our first question therefore is: "What is a dietary supplement?" Prior to the Dietary Supplement Health and Education Act (DSHEA) of 1994, of which we will have much to say, the term dietary supplements referred to products consisting of one or more of the essential vitamins, minerals, and proteins. With DSHEA, that now includes any, repeat, any product intended for consump-tion—ingestion—as a dietary supplement, which includes botanicals (vegetable), herbs (plant), amino acids, enzymes, concentrates, metabolites, and, of course, vitamins and minerals. It is easy to spot a supplement as the law requires manufacturers to label their products as "dietary supplements." These can be pills, capsules, powders, and liquids, and are sold in supermarkets, grocery stores, discount chain stores, drugstores (pharmacies), hotel resorts, and healthfood stores, as well as on TV and radio, via the Internet, mail order catalog, and direct sales. Think about this range of outlets in terms of FDA and FTC oversight. The Federal Trade Commission is charged with regulating the advertising of dietary supplements, but can either the FDA or the FTC adequately monitor this diversity of outlets?

Dietary supplements (see list of uses in Table 2.1) by law are not drugs, not medicines, not pharmaceuticals. However, and nevertheless, Internet Websites make these claims for dietary supplements:

• "Can improve circulation ... peripheral vascular insufficiency."

• "Is effective in treatment of mild to moderate depression."

• "Because it has natural antibiotic action, echinacea is an excellent herb for infections of all kinds."

• "This extract of Saw Palmetto is the most widely used herbal preventative and therapeutic agent for benign prostatic hyperplasia."

TABLE 2.1. The Diverse Uses of Supplements





















a The fact that these total more than 100% suggests they are being used for more than one condition.

a The fact that these total more than 100% suggests they are being used for more than one condition.

If dietary supplements are medicines—drugs—as these claim simply, they must be preapproved by the FDA prior to marketing, which means that their manufacturers are required to have filed both animal study data along with human clinical trial data supporting efficiency and safety. The food and drug laws place the burden of proof on food and drug manufacturers, as well they should. And it is accepted. But dietary supplements are not being sold in supermarkets, discount chains, and drugstores as drugs or medicines. Are dietary supplements in fact foods? What is a supplement? Here we arrive at our conundrum.

Dietary supplements are not true foods. If they were foods, their manufacturers would also be required to produce the animal and human documentation supporting their safety and efficacy, as drugs do. But they haven't. Because they are not foods. What are they, then? Supplements. According to the dictionaries I ' ve perused, a supplement completes or makes an addition. So a dietary supplement is sort of "neither fish nor fowl." Neither a food nor a drug. What are these things that are flying off the shelves? Buyers are grabbing products that I've dubbed the "un"s: untested, unregulated, unstandardized, and of unknown effects: an entirely new concept for the marketplace, and one that makes consumers responsible for knowing what it is they consume— assuming also that what they purchase is safe and efficacious; an erroneous assumption—nevertheless, it is an assumption engendered over long years of purchasing food and drugs, and extended, quite rightly, to all products in the marketplace. Security and reliability had been achieved.

That security was first obtained in 1906, with the passage of the Pure Food and Drug Act, and was further ensconced in 1938 with authorization of the Food, Drug and Cosmetic Act, and reaffirmed yet again in 1960, when Congress decreed that both food and drug manufacturer' s provide substantive evidence of efficacy and safety to the FDA's satisfaction prior to marketing—a requirement that has worked well and provided the security that we have come to assume. But trouble was brewing.

In 1989, the amino acid l-tryptophan arrived in the marketplace extolling its talents as an antidote for postmenopausal syndrome, anxiety, and sleep disorders. During that year, 38 people died, while another 1500 incurred connective tissue disorders—underreported estimates—which impelled the FDA to empanel a taskforce to investigate the supplement industry. The panel recommended that over-the-counter sales of amino acids and other supplements be stopped and dosages of vitamins and minerals be sharply limited [1].

With the taskforce's recommendations in hand, the FDA sought Congressional approval for preapproval of all health claims before supplement manufacturers could market their products. They also requested the power to levy fines and penalties. Enter Orrin Hatch. Orrin Hatch, Senator from Utah, is clever and powerful—a wicked and effective combination. In 1992, he forced the passage of legislation barring additional supplement regulations, and orchestrated a highly successful campaign convincing the nation that the government was about to curtail their use of vitamins. Congress was deluged with anti-FDA missives. With an unsuspecting and credulous public behind him, and supplement industry lobbyists and lawyers working with him, they crafted what became Public Law 103-417, the Dietary Supplement Health and Education Act of 1994 (DSHEA), which was to turn established health protection on its head [2].

At the outset, we are informed that "Congress finds that the importance of nutrition and the benefits of dietary supplements to health promotion and disease prevention have been documented increasingly in scientific studies " —a blatant fabrication if ever there was one. But it was Section 403 B(c), Burden of Proof, that left us vulnerable in the marketplace and returned caveat emptor—let the buyer beware—to center stage.

In any proceeding brought under Subsection (a), the new law informs us, "The burden of proof shall be on the United States to establish that an article or other such material is false or misleading" [2] , Short, definitive, absolute. The tables were turned. The supplement manufacturers were off the hook. The government was now responsible for what the supplement fabricators placed on store shelves. Why? Why surrender the public's only source of protection for the benefit of the supplement industry, an industry that had never demonstrated its need in American life? When questioned about this on the Senate floor, Hatch declared that the FDA had "repeatedly attempted to impose unnecessarily stringent standards that would leave many if not most supplement companies with no practical choice but to close their doors" [2]. Clear enough. The public came in last, and would have to fend for itself. The industry was there to make big bucks, which was what really counted. Is it any wonder that Orrin Hatch is referred to as the "Godfather of the supplement industry"? This kindles a cautionary tale. Groucho Marx interviewed Louisiana State Senator Dudley J. LeBlanc about a "miracle" cure-all vitamin (and mineral) tonic called Hadacol that the senator had concocted. When Groucho asked the senator what it was good for, LeBlanc answered with surprising honesty: "It is good for five and a half million for me last year" [3]—enough said.

Indeed, the Act created a new class of products removed from FDA purview and jurisdiction, yet another "un" —the untouchables. Under DSHEA the floodgates opened wide and the products, some 30,000 of them, poured through. And the buyers were there, ready to be the supplement industry's guinea pigs. Why? Simply because none of the manufacturers have done, or care to do, the necessary studies. Why should they? It's not required. And when was the first, or last time anyone asked, "Was this product I've bought even evaluated for safety or effectiveness?" At least safety. Really, there is a great lack of incentive on the part of supplement manufacturers to undertake product studies. They take time. Laboratory animal studies and human clinical trials require professional talent to conduct, and can be quite costly. But most importantly, they can bear ill tidings: un (another "un") favorable results, unwanted, undesirable results—that the product is either unsafe or ineffective, or both. As of 2005, of the literally thousands of products on market shelves across the country, perhaps a half-dozen have been tested for safety. Most disquieting is the fact that since its inception in 1998, the National Center for Complementary and Alternative Medicine, one of NIH ' s 17 Institutes and Centers, has provided millions of dollars in grants for research studies on many of the most sought after supplements, and has yet to obtain positive beneficial findings for any of them [4]. To be sure, at this point, with supplements sales in the double-digit billions of dollars, it obvious that supplements are a triumph of marketing over science and medicine.

Furthermore—and how this one got away from the FDA is yet another triumph for industry lawyers and lobbyists, over public safety—DSHEA makes it clear that supplement manufacturers are not required to provide reports of adverse events to the FDA. Reporting is voluntary, and the only way the FDA learns of ill effects or deaths is from individual physicians, hospitals, or individuals who take the time to report an untoward event. Currently all negative events are only rough estimates. With the passage of DSHEA the FDA has been running on empty. Until DSHEA is amended, the public is on its own. Caveat emptor should become the country's motto.

Knowing how this anomaly occurred, the answer to our first question may help us with the second: What is it that we are purchasing and ingesting; what are we getting for our money, and how are these supplements being used?

This aggregation is particularly revealing in that these items exhibit a common feature; they are all common medical problems. Evidently supplements are being used as medicines, to treat illness. Users are in fact doing exactly what DSHEA intended: making their own medical decisions, choosing whatever medications, therapies, they prefer in a marketplace unfettered by government regulation, and protection. But do we possess the knowledge to make these decisions? Do we need know only what labels tell us? What in fact do they tell us—or fail to tell us?

Under DSHEA, supplement labels can carry one of three types of claims: nutrient content claims, disease claims, and nutrition support claims, which include structure function claims. Because these diverse claims can and do cause confusion, and offer no assistance in making choices or protection from inaccurate, misleading, or fraudulent claims, we shall parse these in some detail.

Nutrient content claims are the simplest in that they note the level of a nutrient ingredient in a supplement. A supplement containing at least 200 milligrams (mg) of calcium per serving could state "high in calcium." A supplement with at least 12mg of vitamin C could state "excellent source of vitamin C." The only problem here may be that what the label states in milligrams, may not be in the container. More about this shortly.

Nutrition support claims may describe a link between a nutrient and a deficiency disease that can result if the nutrient is lacking. In this case, the label of such a supplement could state that vitamin C prevents scurvy. But if so stated, the label must also note the prevalence of that deficiency in the United States. Current data suggest one or two cases in the entire country.

Disease claims are intended to connect nutrient or ingredient with a disease-or health-related condition. An example is the water-soluble vitamin folic acid, which is known to decrease the risk of neural tube defects when taken by women during pregnancy. If, and only if, the supplement contains a sufficient amount of folic acid to accomplish this, can it be so stated on the label? Similarly, it is believed that calcium can lower the risk of osteoporosis. If the supplement contains a sufficient amount of calcium, it can make the connection on its label.

Nutrition support claims are not the same as nutrition content claims. Nutrition support claims can describe a link between a nutrient and a deficiency disease that can occur if the nutrient is lacking from the diet.

Ergo, the label of a vitamin C supplement (ascorbic acid) could state that vitamin C prevents scurvey, but, given the rarity of the disease in the United States, the label must also mention the prevalence of that disease in the U.S.

Possibly the most troublesome claim is the structure-function claim, which refers to the supplement's effect on the body's structure or function, including its overall effect on a persons well-being. For example, claims such as calcium builds strong bones, antioxidants maintain cell integrity, and fiber maintains bowel regularity, are current examples of structure-function claims.

Lets be clear about this. Structure-function claims describe how consuming the supplement will affect a structure such as the skeletal system, or a function such as the circulatory system, or a person's general well-being, but do not— cannot—claim to reduce the risk, prevention, or treatment of a disease. This is essential. It can be claimed that the supplement "supports the immune system," or "helps support cartilage and joint function." Unfortunately, "supports" is too often translated as "treats," or buyers assume that it treats, which is exactly what the manufacturers intend. Because structure-function claims can be so interpreted, all—repeat, all—structure-function products most carry a disclaimer on their labels. This disclaimer is free of ambiguity. It states that "these statements have not been evaluated by the FDA. This product is not intended to diagnose, treat, cure or prevent any disease." Could anything be clearer? Who would purchase a supplement that could accomplish none of those? Lots of people. Why? Because in the ongoing conflict between the FDA and the industry lawyers and lobbyists, the FDA lost the battle of size of print and placement of the disclaimer. The container on the right in Figure 2.1 clearly shows the required asterisk immediately after the claim, telling the reader to look for a footnote, the disclaimer. But do not expect to see such clarity on labels in supermarkets or other stores. Think of it as a game. Tip: Bring a magnifying glass. Finding the disclaimer is a cat- and- mouse affair between the FDA, manufacturers and consumers. But it isn't a game. Not a sport. Not a joke. It may be a comedy of errors that the FDA allowed itself to be part of. On the face of it, the idea of a footnote is nonsense. And the manufacturers took advantage of it by loading their labels with all manner of messages used as camouflage to hide the disclaimer. It would be illuminating and educational to visit your local emporium and dally among its supplement

Fda Dietary Supplement Disclaimer
Figure 2.1. Comparison of two products with and without the required FDA disclaimer. (Source: U.S. GAO/RCED-OO-156, Dietary Supplements and Functional Foods.)

aisles. Pick up a selection of containers, boxes, and bottles. Read the labels. Ask yourself, what these messages and statements mean. What in fact is this supplement supposed to accomplish? Check for the disclaimer. I read a label on one product that had a cut-down version. It said, "not intended to diagnose, treat, cure, or prevent any disease." Not a word about the FDA not having evaluated the label statement. That's the last thing they want on their labels.

But that is not the end of it. Manufacturers are tying their products to articles published in scientific journals—no matter how tenuous. Figure 2.2 is a grand example. Juvenon is new to the supplement world. This ad is from the popular and sophisticated magazine Scientific American. And here, Juvenon informs us that their product is backed by the research done at UCLA (University of California, Los Angeles), and they cite the article published in one of the most prestigious journals. Fine. But what they don't tell us is that the research was conducted on rats, and doesn' t even hint at possible use in humans. But it does sound very scientific, and proceeds from the well-known psychological fact that people overestimate the importance of presented information, and underestimate the importance of information that was not presented [5]. By the way, with third-party information such as this, the FDA requires that the information be "truthful, nonmisleading, and present a balanced view of the available scientific information." The statements in Figure 2.2 are beyond a stretch of the truth, and are decidedly misleading. But who is going to bell the cat? The Internet poses even greater problems. Can the FDA monitor the Internet for dubious references, or protect against doublet ongued, direct- t o- consumer marketing? So, for example, an Internet pitch

Figure 2.2. Supplement advertisement made to appear scientifically sound. Where is the disclaimer?

referred to a 1931 publication recommending St. John's Wort for pulmonary complaints, and championed the perennial herbal product comfrey, which the FDA had advised manufacturers to remove from markets because of its evident hepatotoxicity [ 6], Furthermore, of 443 Internet sites studied, the required disclaimer was omitted on over 50% [7]. No, it's not a game. Caveat emptor (buyer beware) must be taken seriously. Now consider this: The FDA's budget allows only three of its staff to work part time investigating reports of health problems associated with dietary supplements. The FDA, like all government agencies, is a creature of Congress; niceties aside, Congress owns them. That's stating it crudely, but factually. no agency can function without a budget, which is Congress' to determine. Congress holds the purse strings. Under DSHEA, the FDA is mandated to protect the health of the public, but not so diligently that manufacturers must toe the line too tightly. Balancing this improbable relationship requires that Congress ensure that the FDA ' s budget has enough, but not enough to protect the public, from unscrupulous manufacturers. You might want to reread that passage. It's factual, but too hard to believe. But believe it you must.

If that isn't enough to worry about, think fraud. My dictionary defines fraud as deliberate deception. Fraudulant products can often be spotted by the type of claims made: a "secret cure," "breakthrough," "miracle cure," "magical," or "a new discovery." Such claims must be seen as signals, tipoffs that the products touting them are palpable frauds. Real cures cannot be kept secret, nor are they miraculous nor magical. Additionally, jargon such as "detoxify," "purify," "energize," and "cleanses the blood" are vague and meaningless terms that should raise red flags, as should claims that a product can cure a range of ills. Not one supplement, or drug for that matter, has all-encompassing capabilities. Moreover, referring back to citations of scientific studies, claims that a product is backed by scientific studies need to pass through a filter of traceable citations, and out- of-date, irrelevant, and/or uncontrolled studies. In addition, claims that the product has only benefits and no side or adverse effects must be taken with the proverbial grain of salt, as any product potent enough to produce physiological effects and responses, will also be potent enough to produce negative side affects.

Finally, a government agency has moved to deal with the egregious marketing of dietary supplements. In March 2006, the Federal Trade Commission slapped the wrist of Garden Life, Inc., and its founder Jules Rubin,with a $225,000 fine for making bogus claims that its products Primal Defense, RM-10, Living Multi, and FYI could cure diseases, and that these products were supported by scientific evidence, which was entirely false. RM-10 was advertised as a concoction of 10 types of mushrooms that could cure cancer. Between 2001 and 2004, Garden Life, Inc., of West Palm Beach, Florida, had sales totaling $58 million. Indeed, $225,000, is no more than a slap on the wrist, and this is the first fine issued against a supplement company in a decade. Whole Foods, GNC, and the Vitamin Shoppe are major sellers of the Garden Lifeline of products.

Wariness must also be extended to products claiming that the government, drug companies, and the medical profession have colluded to keep this beneficial information from you, and that they didn't want you to know about this product; this is patent nonsense simply because it would be impossible for such collusion to occur. Indeed, consumers are faced with a confusing array of claims, some that require rigorous scientific support and others that can be made with less evidence, but with no clear way to distinguish between them. Even when products have made unsupported structure-function claims, the FDA has not taken enforcement action. Consequently consumers can, and do, make inappropriate choices and purchases, and rely on ineffective products to treat their health problems. The line (demarcation) between label requirements and pure advertising has disappeared. So what happens when adverse effects occur, and how does the FDA learn about them?

Do supplements produce adverse effects? Of course, they do. But—and this is a preeminent "but"—firm numbers are exceptionally difficult to come by, and those that are available are estimates, rough estimates at that, due to underreporting. A study published in 2003 noted that of 11 poison control centers around the country, 20% of the total number of centers, and which contribute some 12% of all events, 1466 cases dealt with ingestion of dietary supplements. The researchers interviewed 489 confirmed supplement users and found that 30% had greater than mild adverse reactions, including myo-cardial infarction, liver failure, bleeding, seizures, and death. Treatment of disease was the reason for supplement use in some 28% of cases. The study's authors were unable to calculate a population-based risk estimate, as they could obtain neither a numerator (events) nor a denominator (numbers using supplements). They were able to estimate that of all the adverse reactions reputed to the 65 poison centers, 17% were contributed by dietary supplements [7]. In another report, the General Accountability Office (GAO) reported that between 1993 and 2003 the FDA received about 3000 reports of adverse affects including 105 deaths. But they also inform us that the FDA's account of adverse affects is at odds with other information. A nationwide consumer survey in 1999 found that 12% of all consumers using a supplement, some 12 million people, said they had experienced an adverse reaction. Obviously few people take the time to report, or don't know where to direct their reports. Also, under DSHEA, the supplement manufacturers are not required to report adverse effects. Is it necessary to repeat that? Ergo, if an adverse event is reported to a company, it is not passed on to the FDA. The entire process is voluntary. Recall that under DSHEA it is up to the FDA to prove a product unsafe. Clearly, the numbers that are available reveal a fraction of the total. How, then, does the FDA identify unsafe supplements? Currently the FDA relies on its Med Watch voluntary reporting system—a system that depends on voluntary reporting of suspected adverse reactions by a person (patient) or healthcare provider who must actually recognize the event as a possible adverse reaction [8]. It is entirely reasonable that most reactions go unrecognized by both patients and professionals as being supplement-related— and even if recognized, less than 10% are reported. When sufficient reports are received, an indication of a possible problem may emerge, but proving causality from case reports is extremely difficult [8]. How anyone can assume that supplements are innocuous is beyond belief. Under DSHEA, it is the marketplace, we, the people, that must prove efficacy and safety, an approach that failed early in the twentieth century and was the reason for establishment of the FDA in the first place. Nevertheless, Med Watch needs support. (It can be reached at 1-800-FDA-1088, or by fax at 1-800-FDA-0178. Their Website can be accessed at

A chemical is a chemical, is a chemical; all is chemical. We have yet to inquire as to what in fact are supplements, and how they differ from traditional drugs or medications. Drugs are biologically active single-chemical substances formulated to achieve a specific physiological response in tissues and cells. Are supplements drugs?

The roots, stems, leaves, and flowers of hundreds of plants sold as powders, gels, and liquids are in fact mixtures of many chemicals. We all know that when ground and roasted coffee is added to hot water, we get a brew of splendid odor, taste, and color. Close to 1000 well-defined chemicals have been identified as contributing to this fragrant beverage. Tea and cocoa are much the same, loaded with chemicals. That's the nature of all plants—of all living things. They don' t just contain a great number and diversity of chemicals; they are nothing but chemicals—some benign, some harmful, some deadly. Because they are natural does not mean that they are safe. Safety and "naturalness" are not necessarily bedfellows. Bear in mind that chemicals obtained from plants were made by plants, for plants, for the many and varied reactions required of the plant to survive and function. Food plants, crops, and herbs naturally account for 99.99% of the pesticides that we ingest. These natural pesticides are manufactured by plants in part to defend themselves against an array of microbes, insects, and animals that crave their succulent tissues. Thus, with the ever-increasing consumption of herbs, regular herb users are among the greatest consumers of dietary pesticides, paralleling the pesticide consumption of vegetarians. It has been estimated that "Americans consume about 1.5 grams of natural pesticides per person per day, which is about 10,000 times more than the synthetic pesticide residues consuned [9].

Any chemical, natural or synthetic, that has an effect on some body function is, ipso facto, a drug. It is simply wrong to think that herbs are an alternative to drugs. They are in fact alternative drugs, a different way of taking a drug—a crude and untested drug, at that.

Taxol (paclitaxel), a chemical and highly effective anticancer drug, was originally obtained from the bark and needles of the Pacific yew tree. Unfortunately, there are not enough yews for all the Taxol cancer patients required because the demand was so great. So Taxol, like so many other drugs originally obtained from plants, was chemically analyzed to produce a synthetic Taxol, indistinguishable from the original, thereby allowing the trees to grow undisturbed. Such synthesis produces chemicals, drugs, whose identity and purity are known, whose quality and potency are assured, and can be made in the quantities needed, time after time. Reproducibility. That's essential.

Herbs, with their naturally occurring mixtures of hundreds of chemicals must have variable potency from season to season, and country to country. With their potpourri of chemicals, can have a spectrum of effects other than, or along with, those of their so-called active principle. There is no denying that drugs they are. Nevertheless, supplement manufacturers scrupulously avoid even a hint that their products be called or thought of as drugs. To do so would place them squarely in the FDA's purview and require full disclosure of efficacy and safety for the purpose intended, prior to marketing. Supplement manufacturers would sooner pet a cobra than put themselves in that position.

With all the St. John's Wort, Saw Palmetto, ginkgo biloba, and echinacea flying off the shelves in the United States, and around the world, is there really enough to go around? Tests show that many supplements do not contain what they say they do. Potency of pills and capsules vary markedly within the same box or bottle.

Ginseng (Panax ginseng) supplements are among the top 10 supplements sold worldwide, and are prepared from a variety of plants, primarily panax-ginseng, the Korean and Chinese ginseng. Another species in the marketplace is the Japanese and Vietnamese Panax quinquefolius. Each has different uses, but all contain ginsenosides (or panaxosides) steroidal ring compounds. Siberian ginseng, Eleutherococcus senticosus, contains eleutherosides that are chemically distinct from ginsenosides.

Researchers at the University of California, Davis, tested 25 preparations of ginseng for purity and potency. Their pharmacologists found that the commercial products tested were properly labeled as to plant genus, but that there was considerable variability in genocide content among products. They also found that the amounts noted on labels were markedly different from the amounts found in their analyses. From their mass spectrographic procedures, they also found that the Siberian ginseng products varied more than did the Asian. Indeed, as noted above, the high demand for ginseng appears to lead to harvesting of immature plants with lower ginseng concentrations, which will affect the overall quality of the products.

Six of the products tested had almost no ginseng. In addition, concentrations of ginsenosides varied by 15-36 times in capsules and liquids and concentrations of eleutherosides varied by 43-200 times in capsules and liquids. In addition, they noted that previous studies had identified bioactive chemicals such as salicyclic acid, vanicillic acid, peptides, polysaccharides, polyacetylenic alcohols, fatty acids, and vitamins and the minerals copper, cobalt, manganese, and arsenic, in the commercial supplements [10]. Note well that these are all undeclared chemicals, none of which are listed on labels.

In another recent publication, researchers at the Faculty of Medicine, University of Toronto, fed ginseng supplements to a dozen healthy test subjects to determine their affects on glycemic and insulinemic regulation. Their findings confirmed the hypoglycemic effects of a batch of American ginseng but not the hyperglycemic effects of a batch of Asian ginseng. They say that "We do not know whether the batches studied are representative, and we do not know whether reproducing the measured ginsenoside profiles will lead to the same (opposite) results." They concluded by stating that consumers and practitioners alike should be warned of the inherent uncertainty of what commercial batches yield [11]. We do not know what we are actually buying!

An earlier report found that the wild-grown Chinese ginseng is different from the farmed or field-grown variety. The wild type sells for up to $1300 per pound [12]. Potency is the name of the game. Each time, every time.

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