December 11, 2017
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  4. Regarding The Issue of Arsenic

To whom it may concern:

Regarding the issue of arsenic in foods and supplements, I can advise you at the outset that arsenic in food and supplements truly is not as dangerous as ConsumerLab would like many potential subscribers to believe.

I do wish ConsumerLab had been more thorough in their discussion of arsenic in their report. ConsumerLab allegedly found 5.4 µg of inorganic arsenic in each serving of Green Vibrance. How dangerous is 5.4 µg of inorganic arsenic per day and how dangerous is 24.3 µg of combined inorganic and organic arsenic? Let’s turn to Dr. Henry A. Schroeder, M.D., who was a major researcher and authority on heavy metals at Indiana University. Dr. Schroeder writes:

“Arsenic is found everywhere on the Earth’s crust in fair sized amounts, comparable to other toxic metals, at about 5 ppm. In seawater, there are 2 to 5 ppb, which accounts for the fact that many seafoods have more arsenic than the FDA limits (2.6 ppm) allow: mollusks, crustacea – prawns and shrimp – fish, fish roe, cod liver oil, herring, even freshwater fish, and most sea animals and plants. This arsenic is not toxic.”

Arsenic toxicity?
This short paragraph from Dr. Schroeder’s book, The Poisons Around Us, identifies for us what may be the primary source of arsenic in Green Vibrance, namely the sea vegetables. It also tells us how potentially dangerous organic arsenic from those sea plants or any land plant in Green Vibrance might be. As he says, “This arsenic is not toxic.” Let me repeat for emphasis, organic arsenic is non-toxic.

If only 5.4 µg of the 24.3 µg, ConsumerLab found in Green Vibrance is inorganic, then the bulk of the arsenic is organic, and lacks toxicity Arsenic itself is rather quickly and efficiently metabolized through methylation in the liver, and then excreted through the urine. 50% to 70% of all ingested arsenic exits via that route. Literature accumulating since the turn of the 21st century indicates that feces, perspiration, and the sloughing of skin cells also serve as avenues of exit for arsenic. Hair and nails additionally serve as sequester points for the metal. Most tissues rapidly clear arsenic, except for skin, hair, and nails. Arsenic from fish and seafood does not even appear to be metabolized or biotransformed, but instead is rapidly excreted unchanged in the urine within 48 hours of ingestion. Even in the case of the most dangerous, inorganic, trivalent arsenic, most is cleared from the body within two days, with final trace amounts finally exiting the body two weeks or more afterwards.

The source of such inorganic compounds would be from arsenic containing pesticides and herbicides, chemicals used in the manufacture of “pressure treated,” rot resistant lumber, or from airborne residue spewed during the smelting of copper ore, iron ore, silver ore, lead ore or gold ore. Inorganic compounds of arsenic do carry a cancer potential, but the amount required is significantly larger than what is contained in Green Vibrance, and even those much larger amounts must be consumed over a very long period of time – meaning years – before there is any danger. In Dr. Schroeder’s words, “Aside from these qualities [referring to inorganic arsenic], arsenic in the environment today appears to be harmless.” And the level of arsenic in the environment has continued to drop since his book was published in 1974.

In my opinion, ConsumerLab did a disservice to the public by presenting incomplete information to their readers about the true nature of arsenic. They failed, purposely, I presume, to acknowledge that organic arsenic is non-toxic. Inorganic arsenic does carry the potential for harm, but you must take significant amounts over a long period of time for the risk of cancer to arise. The small, 5.4 mcg of inorganic arsenic ConsumerLab found is about half the lower tolerable amount EPA accepts in drinking water. In water, arsenic is also far more bioavailable, meaning that inorganic arsenic in food is far less dangerous. Additionally, within 48 hours of ingestion, nearly all inorganic arsenic is excreted. Human biochemistry is quite efficient at removing both organic and inorganic arsenic. This ability developed over millions of years of adaptation to our food supply.

Speaking from a biochemical point of view, it is possible to say everything you eat is contaminated with a host of substances, including arsenic, that your body does not need, does not want, and that may be poisonous. There is no single food on the planet that is only nutritious. 40% of a carrot is toxic, for example. Every plant contains natural substances, compounds, alkaloids, heavy metals, that are all naturally present, and that must be denatured and excreted from the body because they are unwanted, unnecessary or dangerous. Arsenic in its various forms is one of those elements, and over the millennia, we have developed efficient means to rid it form our bodies.

Green Vibrance, GMPs, Regulation
That Green Vibrance may, as ConsumerLab alleges, deliver 5.4 mcg of inorganic arsenic in a dose, does not mean that we accept 5.4 µg of inorganic arsenic as the way of the world, and something we can do nothing about. On the contrary, our discussions within the halls of Vibrant Health have resulted in an entirely new procedure that goes beyond Good Manufacturing Practices (GMP) standards for the tracking and recording of heavy metals in all raw materials and finished products. A person within our production team has now been assigned the specific role to closely monitor all heavy metal and microbiological data associated with each ingredient, AND to identify fluctuations in those values with the goal toward further reducing the content of all heavy metals in both ingredients and finished products.

Green Vibrance contains 73 ingredients selected with care to be of the highest quality. If the accumulated, naturally occurring trace amounts of arsenic in these plants should deliver 5.4 µg of inorganic arsenic (a test result we have not yet corroborated) then that simply reflects the natural presence of such compounds in food. Indeed, selenium is known to help in the methylation and detoxification of arsenic, and Green Vibrance provides a significant dose of 106 µg of selenium per serving, according to our latest analysis. Selenium also provides essential antioxidant protection at the cellular level to further protect against the oxidative action of heavy metals. Other antioxidants such as vitamin C and the rich complement of polyphenols supplied by botanical extracts in Green Vibrance are additionally known to protect against and detoxify arsenic. (These facts demonstrate that Green Vibrance is balanced, healthful and coordinated in its formulation.)

Every raw material purchased by Vibrant Health is accompanied by a heavy metal analysis and a microbiological analysis. Furthermore, we only purchase from reputable raw material suppliers with international and industry wide reputations for quality. We ourselves use Covance laboratories, Silliker labs, Eurofins, Chemical Solutions and, occasionally, Advanced Laboratories as our own, impartial outside testing labs. Furthermore, we use only GMP certified contract manufacturers to assemble our materials into finished products. EACH of these manufacturers has their own in-house laboratory that retests and corroborates each material in accordance with GMP regulations. If they should find a discrepancy between their analytical results and that stated on the certificates of assay that accompany the materials, we are alerted. Our response is to have the material retested by an outside lab (one of those listed above), and then examine the results. From time to time, but not too often, we find it necessary to reject a raw material. We have in the past rejected materials because of either microbiological contamination or lead levels that were too high. Nothing has yet failed due to elevated arsenic levels.

As a side note, we all hear from time to time about the unregulated nature of the dietary supplement industry. We hear from Sen. Dick Durbin of Illinois, from news pundits, from authorities under the influence of the pharmaceutical industry, and from physicians who are ignorant about alternative methods of healing, that the supplement industry is unregulated. Nothing could be farther from the truth. Not only does the supplement industry fall under the aegis of the Dietary Supplement Health Education Act of 1993 (DSHEA), but it is also regulated by a thorough set of Good Manufacturing Practices (GMPs). One of the primary reasons why dietary supplements have become more expensive over recent years is because of the layers of regulation that sit upon the industry. Raw materials must be analyzed by the raw material manufacturer, by the company that manufactures the product and by the company that markets the product. There is triple redundancy built into the process to check identity, microbiological integrity and heavy metal levels. Companies that do not follow the very stringent GMPs (Good Manufacturing Practices) are cited, fined and occasionally closed down by FDA.

But how can you know that? You can’t, because you do not work inside the industry. And so the media has an opportunity to turn your attitude against dietary supplements or specific members of that community. We who do work within the industry are well aware of our current and effective level of regulation. Over my 42 years in dietary supplements, I have seen supplement manufacturing migrate from what truly was an unregulated industry to one that is highly regulated.

In the end, I must strenuously object to ConsumerLab’s use of the term “highly contaminated” in describing the naturally occurring level of arsenic in Green Vibrance. The use of such an unfounded, hyperbolic comment can only be meant to incite a negative public reaction. Inciting fear is even more egregious in light of the facts that human exposure to inorganic arsenic has been dropping for decades and that the amount in Green Vibrance is so small.

Arsenic in plants will be organic, unless the crops have been sprayed with inorganic arsenic containing herbicides or insecticides. However, the use of such agricultural chemicals has been dropping steadily since the mid-1960s when they were abandoned in favor of newer, arsenic-free herbicides and pesticides. Indeed, from 1964 to 1974, human exposure to both organic and inorganic arsenic dropped by 50%, primarily due to the discontinued use of arsenic containing agricultural chemicals.

These drops are in line with reductions of other metals in our environment, lead foremost among them. Lead levels in foods have declined over time in many developed countries. Elimination of lead additives from most gasoline in the 1970s and from paints is credited with much of the reduction in exposure. The cutback in industrial use has dramatically benefitted the food supply. From 1980 to 2006, lead levels in food dropped 75% in New Zealand, 95% in the United Kingdom, and 50% in France and Canada. In the U.S., lead intake by teenage males declined from 70 mcg per day in 1976 to 3.45 mcg in 2000, another 95% drop.

Due to the replacement of arsenical insecticides and herbicides by organic forms, the presence of inorganic compounds in and on foods continues to decline. Nevertheless, the attention given to inorganic arsenic by ConsumerLab’s report has caused us to alter our procedures for heavy metal testing. We will now, and into the future, no longer conduct the standard arsenic analysis, which shows the combined arsenic content of both organic and inorganic forms, but will instead invest in the more expensive analysis that separately identifies both organic and inorganic arsenic.

Given that we use as many certified organic plant materials in Green Vibrance as possible, the presence of trace amounts of inorganic arsenic in each serving of Green Vibrance provides evidence of the inescapable worldwide presence of the metal in our environment.

I would urge ConsumerLab to be honest and thorough in their approach to their analyses and thereby expand their reach to include every super green food in the marketplace. A true analysis will show that a dietary supplement cannot be manufactured from plant-based ingredients and NOT contain some level of heavy metals. At the same time, I suggest analyzing some fresh whole foods for comparison.

The ultimate problem, if there is one of course, is that natural foods anywhere on the planet contain some level of heavy metals. At Vibrant Health, we do indeed buy our raw materials based not only on their high nutritional density but also their low heavy metal content.

To Summarize:

  1. We wish Consumerlab had contacted us before publishing their report, so that we could have provided them with a helpful response.
    2. We do indeed screen all of our ingredients for heavy metals, and, for example, have one of the lowest heavy metal levels among all green foods.
    3. The amount of arsenic in the plant materials in Green Vibrance is not unusually high.
    4. The 5.4 µg per serving of inorganic arsenic presents no short or long-term danger.
    5. Our selection of quality ingredients has actually reduced the level of all heavy metals in all of our finished products since the company’s inception in 1992
    6. Similar and higher levels of arsenic are encountered in all fresh plant foods.
    7. Plants and plant foods are the most concentrated sources of micronutrients
    8. A dietary supplement manufactured from plants will naturally bring along certain amounts of minerals and metals.
    9. The human body has dealt with these natural, toxic compounds for millions of years, and has established adequate and efficient means to eliminate them.
    10. Arsenic is rapidly excreted from the body. Its danger has been overstated by ConsumerLab.
    11. Micronutrients and fibers in Green Vibrance assist in the detoxification and elimination of heavy metals.
    12. Although Green Vibrance may contain arsenic, as will any natural plant food, it is also carefully constructed to contain micronutrients that protects against arsenic.
    13. Green Vibrance has been used daily by thousands of people for more than 20 years, delivering tremendous health benefits.
    14. We will continue to work diligently to further reduce heavy metal metals to the lowest possible level.
    15. Green Vibrance is no more poisonous – and is indeed far more healthful – than any other natural or whole food a person might consume.

Postscript: Further reading on ConsumerLab.

You may find these links informative, although I won’t vouch for their journalistic quality. (I was surprised to see that our attorney who specializes in FDA matters, Marc Ullman, is quoted in the first article.)

Learn more about arsenic: Arsenic FAQ

About the author: Mark Timon is the founder of and formulator for Vibrant Health.  He entered the nutrition industry February 5, 1971, and designed over 450 nutritional supplements for other companies before founding Vibrant Health in 1987. His formulations are noteworthy for their completeness and synergistic balance. They are based on rigorous research and study, in combination with his experience in Clinical Nutrition. Mr. Timon holds a bachelor’s degree from the University of Colorado, and a Masters degree in Biology, Emphasis in Clinical Nutrition, from the University of Bridgeport, Bridgeport. Connecticut. He has authored The Complete Dictionary of Health and Nutrition, and published a number of articles on health and nutrition that have appeared in the Townsend Letter for Doctors and in lay publications.

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