UK has proposed very inadequate vitamin D levels and has asked for comments
Download the SACN draft from VitaminDWiki
UK proposes that 10 ng level and 400 IU is enough Vitamin D for everybody (no and no)- July 2015
UK Govt committee side line new Vitamin D Science Sept 2015
"ANH-Intl has filed a submission which is deeply critical of the bottom line recommendation, which remains unchanged from previous reviews going back to 1991."
- The SACN has cherry-picked data;
- The SACN has not taken into account the problems with vitamin D intake studies;
- The SACN has misinterpreted available data on the effects of genetic polymorphisms on vitamin D requirement;
- The SACN has not sufficiently accounted for the effects of increased body weight and use of sunscreens;
- The SACN has ignored expert evidence;
- The SACN has ignored differences between vitamin D2 and D3;
- The SACN has ignore emerging evidence for the role of elevated vitamin D status on reducing the risk of certain cancers;
- The SACN has not proposed different recommendations for different racial groups/skin colours,
- The SACN has not considered that there are likely to be overlapping risks and benefits;
Related item update:US admits math mistake was made in 2010 in estimating Vitamin D, but will not change recommendations – Nov 2017
Comments by Dr. Fischer UK
Comments by R. Greenbaum
Download Greenbaum Sept 23, 2015 PDF from VitaminDWiki
To: Secretariat, Scientific Advisory Committee on Nutrition ( SACN ), sacn at phe.gov.uk
From: Rufus Greenbaum ( www.rufusgreenbaum.com )
Date: September 23, 2015
Re: Comments on the Draft Vitamin D and Health report of July 22, 2015
My primary concern is that Vitamin D should be considered as a medical and health matter rather than being based on nutrition. For this reason individual health topics should also be considered by NICE.
I am disturbed that you set an arbitrary definition of Vitamin D Deficiency very early in your work. You announced that the definition would be set at 25 nmol/L, whereas the IOM set it at 50 nmol/L. In my submission to SACN I pointed out that there is good evidence that a level of at least 75 nmol/L is required for good bone health and that a group of experts have recommend a target level between 100-150nmol/L.
Please explain why the UK should set a target of 25nmol/L
In this document I will refer to a wide range of illnesses by reference to 3 major websites that have significant information about Vitamin D:
www.vitamindcouncil.org 44 health conditions reviewed
www.vitamindwiki.com 60 health conditions prevented or treated
www.grassrootshealth.net Blood serum level of 100-150 nmol/L to prevent illness
A brief review of these websites will show that there are health benefits from maintaining Vitamin D blood levels higher than your arbitrary level of 25nmol/L
In addition, since Vitamin D is fat soluble and different people absorb different amounts, the medical focus should be on the measured blood level rather than the input or nutritional amount
There is a major omission by not making a significant review of Type 2 Diabetes
https://www.vitamindwiki.com/Overview+Diabetes+and+vitamin+D
http://www.vitamindcouncil.org/health-conditions/
The draft report has omitted reference to a number of other significant health conditions:
Acne, Anaphylaxis, Anaemia/Anemia, Back Pain, Fibromyalgia, HIV & AIDS, Melanoma, Myeloma, Parkinson’s, Psoriasis, Sepsis, Thyroid conditions and Trauma.
https://www.vitamindwiki.com/VitaminDWiki
http://www.vitamindcouncil.org/health-conditions/
The rest of these comments will refer to Paragraph numbers in the Draft Report
These comments are my private views, based on information about Vitamin D and many health conditions collected since 2009, and including previous formal submissions to the SACN
86. Infants
Infants need Vitamin D and calcium, preferably from the mother
https://www.vitamindwiki.com/Overview+of+Rickets+and+Vitamin+D
http://www.vitamindcouncil.org/health-conditions/rickets
87. Children and Adolescents
Children and adolescents need higher levels of Vitamin D and calcium for more than bone development. Having a good level of vitamin D cuts in half the amount of: Asthma, chronic illness, doctor visits, allergies, inner ear infection, respiratory tract infection, growing pains and bed wetting
https://www.vitamindwiki.com/Infant-Child
88. Adults
Adults need higher levels of Vitamin D for more than bone development
http://www.vitamindcouncil.org/health-conditions
https://www.vitamindwiki.com/Proof+that+Vitamin+D+Works
http://grassrootshealth.net/media/download/dip_with_numbers_8-24-12.pdf
90. Pregnancy & Lactation
Women should boost their level of Vitamin D at least 3 months before considering conception.
This will improve their chances of becoming pregnant
In one trial women were given 100 micrograms of Vitamin D3 each day during their pregnancy. From this and other trials there is evidence that higher Vitamin D leads to an easier pregnancy with less Bacterial Vaginosis, Gestational Diabetes, Pre-Eclampsia, dental problems, emergency C-sections and fewer pre-term births.
If the pregnant woman has higher levels of Vitamin D their children have less Rickets, fewer seizures, less diabetes, less asthma> Development of the child is generally improved, with one trial showing fewer language problems at age 5
https://www.vitamindwiki.com/Overview+Pregnancy+and+vitamin+D
If the mother has higher levels of Vitamin D after birth then her breast milk will have adequate levels of Vitamin D for her baby. She will also have a reduced risk of post-natal depression.
There is strong evidence that boosting a woman’s 25(OH)D to 100 nmol/L will reduce pre-term births to half the normal level, across different groups of ethnicity and skin colour.
There is more information at: https://www.youtube.com/watch?v=5jUU4rAQ8lE
155-158 Target blood levels
The IOM set 40 nmol/L as the level where 50% of the USA population have an adequate level and 50 nmol/L as the target for 97.5% of “normal, healthy persons”
The Endocrine Society suggests:
to maximise the effect of Vitamin D on calcium, bone and muscle metabolism, serum 25(OH)D should exceed 75 nmol/L
Please explain why the UK should set a target of 25nmol/L
184. Disease Prevention or Cure
I note that this report only deals with disease prevention
NICE Guidance should consider whether Vitamin D should be used for treatment
199-212 Bones
Lifelong improvement in bone health is more likely if serum 25(OH)D is above 75 nmol/L. Priemel et al measured the bone health from 675 people who had recently died and the interpretation of their data by Dr Robert Heaney suggests that values below 75-80 nmol/L “cannot be considered as adequate”
__
282-289 Military Bone & Muscle Strength
There are many reports from the military where stress fractures are reduced when 25(OH)D is higher. They are an ideal group where controlled experiments have and can be done.
https://vitamindwiki.com/tiki-index.php?page_id=5892
328-344 Falls
There is a Cochrane Review that shows that falls in the elderly are reduced when Vitamin D serum and Calcium levels are higher.
This results from stronger bones and muscles
https://www.vitamindwiki.com/Overview+Fractures+and+Falls+and+Vitamin+D
356-391 Pregnancy & Lactation
Women should boost their level of Vitamin D at least 3 months before considering conception.
This will improve their chances of becoming pregnant
In one trial women were given 100 micrograms of Vitamin D3 each day during their pregnancy. From this and other trials there is evidence that higher Vitamin D leads to an easier pregnancy with less Bacterial Vaginosis, Gestational Diabetes, Pre-Eclampsia, dental problems, emergency C-sections and fewer pre-term births.
If the pregnant woman has higher levels of Vitamin D their children have less Rickets, fewer seizures, less diabetes, less asthma and development of the child is generally improved, with one trial showing fewer language problems at age 5
https://www.vitamindwiki.com/Overview+Pregnancy+and+vitamin+D
If the mother has higher levels of Vitamin D after birth then her breast milk will have adequate levels of Vitamin D for her baby. She will also have a reduced risk of post-natal depression.
There is strong evidence that boosting a woman’s 25(OH)D to 100 nmol/L will reduce pre-term births to half the normal level, and reduce current disparities between many different groups of ethnicity and skin colour.
There is more information at: https://www.youtube.com/watch?v=5jUU4rAQ8lE
392-404 Cancers
There is evidence that levels of Vitamin D above 100 nmol/L help to prevent and treat many cancers.
There is good evidence for cancers of the Breast, Cervix, Colorectal, Esophogus, Stomach, Lung, Ovaries, Pancreas and Prostate
https://www.vitamindwiki.com/Overview+Cancer+and+vitamin+D
http://www.vitamindcouncil.org/health-conditions
405-418 Cardiovascular disease
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Cardiovascular disease.
https://www.vitamindwiki.com/Overview+Cardiovascular+and+vitamin+D
http://www.vitamindcouncil.org/health-conditions
419-428 Hypertension
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce hypertension by typically 5-10 mm Hg and should be used as part of a range of treatments
https://www.vitamindwiki.com/Hypertension+and+vitamin+D
http://www.vitamindcouncil.org/health-conditions
429-436 All Cause Mortality
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce death from all causes
https://www.vitamindwiki.com/tiki-index.php?page=Mortality
437-470 Autoimmune diseases
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many autoimmune diseases
https://www.vitamindwiki.com/Autoimmune
441-450 Asthma
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Asthma
https://www.vitamindwiki.com/Overview+Asthma+and+Vitamin+D
http://www.vitamindcouncil.org/health-conditions/
451-454 Diabetes
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat both Type 1 and Type 2 Diabetes
The draft report only mentions Type 1 Diabetes
It is a pity that Type 2 Diabetes was not reviewed, as there is significant benefit from increased levels of Vitamin D
https://www.vitamindwiki.com/Overview+Diabetes+and+vitamin+D
http://www.vitamindcouncil.org/health-conditions/
455-456 Inflammatory Bowel Disease & Crohn’s disease
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat all forms of Inflammatory Bowel Disease and Crohn’s disease
A number of Gastroenterologists regularly treat these diseases by boosting the level of Vitamin D – with good results
https://www.vitamindwiki.com/Inflammation
http://www.vitamindcouncil.org/health-conditions/
457-460 Multiple Sclerosis
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Multiple Sclerosis
https://www.vitamindwiki.com/Overview+MS+and+vitamin+D
http://www.vitamindcouncil.org/health-conditions/
There are reports from Brazil of doctors boosting Vitamin D to 250 nmol/L as part of a range of therapies to treat Multiple Sclerosis
https://www.vitamindwiki.com/tiki-index.php?page_id=5279
461-462 Rheumatoid Arthritis
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Rheumatoid Arthritis
https://www.vitamindwiki.com/Overview+Rheumatoid+Arthritis+and+vitamin+D
463-464 Lupus
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Lupus
https://www.vitamindwiki.com/Lupus
http://www.vitamindcouncil.org/health-conditions/
471-500 Infectious Disease
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many forms of Infectious diseases
https://www.vitamindwiki.com/VitaminDWiki
http://www.vitamindcouncil.org/health-conditions/
477-484 Tuberculosis
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Tuberculosis
https://www.vitamindwiki.com/Overview+Tuberculosis+and+Vitamin+D
http://www.vitamindcouncil.org/health-conditions/
485-494 Respiratory Tract Infections
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Respiratory Tract Infections
https://vitamindwiki.com/tiki-index.php?page_id=3873
http://www.vitamindcouncil.org/health-conditions/
495 Chronic Obstructive Pulmonary Disease
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Chronic Obstructive Pulmonary Disease
https://www.vitamindwiki.com/COPD+helped+by+weekly+50%2C000+IU+Vitamin+D+%E2%80%93+several+trials
http://www.vitamindcouncil.org/health-conditions/
501-519 Neuropsychological functioning
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many forms of Neuropsychological functioning
http://is.gd/Neuropsychological
503-506 Cognition and dementia
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many health problems with Cognition and dementia
https://www.vitamindwiki.com/Alzheimers-Cognition+-+Overview
http://www.vitamindcouncil.org/health-conditions/
507-511 Depression
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many forms of Depression
https://www.vitamindwiki.com/Depression
http://www.vitamindcouncil.org/health-conditions/
512 Autism
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many forms of Autism
https://www.vitamindwiki.com/Overview+Autism+and+vitamin+D
http://www.vitamindcouncil.org/health-conditions/
513-516 Schizophrenia
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many forms of Schizophrenia
https://www.vitamindwiki.com/tiki-index.php?page_id=2985
520-528 Oral health
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat many forms of Oral health
https://www.vitamindwiki.com/Dental
http://www.vitamindcouncil.org/health-conditions/
530-537 Age Related Macular Degeneration
There is evidence that levels of Vitamin D between 100-150 nmol/L help to reduce and treat Age Related Macular Degeneration
https://www.vitamindwiki.com/Vision
End