Comments to the National Organic Standards Board

December 26, 2012

At the April 2011 NOSB meeting in Seattle, two NOSB members asked during my testimony what NOSB "should do ... in terms of the issue of moving forward on vitamins, nutrients and minerals — with open-endedness, or with citations" — and whether "PCC consumers know that most of the essential vitamins and minerals are synthetic?"

That is the issue before us now with this public comment period on USDA's "Interim Rule on nutrient vitamins and minerals."

We are pleased to answer the questions posed to us on nutrient additives, based on findings from a survey of our organic shoppers in September 2011. A description of the methodology is available in the survey, attached.

The final respondent base totaled 1,432. Responses submitted electronically (1,349) and in writing (171) were combined for analysis. A subset of responses from PCC shoppers was excerpted for analysis and reporting purposes. Included in this subset were survey participants who answered "About what portion of your grocery purchases is certified organic?" (Survey participants who resided beyond PCC's trade area — outside of King and Snohomish counties, Washington state — were excluded.)

The survey was designed to determine awareness and concerns about the source — and regulation of — natural and synthetic nutrients added to organic foods. 43.4 percent of the respondents say they purchase 75-100 percent organic foods, 29.8 percent say they purchase 50-74 percent organic foods.

We conclude from analysis of the data that organic consumers would not support the interim rule that would allow indiscriminate addition of synthetics deemed as "nutrients" to organic foods.

Any suggestion that NOP standards could list only nutrients "required by the FDA to the food to which they are added" is very misleading.

FDA apparently does not require addition of any synthetic nutrients to any foods, with the exception of vitamin A to reduced-fat and skim milk for interstate commerce.

PCC shopper survey findings

  • Almost 8 out of 10 (77.8%) shoppers do not believe FDA ensures added nutrients are effective and safe before allowing them on the market.
  • Only about 16% of shoppers deliberately choose foods because they're labeled as containing added vitamins, minerals or other nutrients.
  • Nearly 90% would not purchase foods with nutrient additives made with synthetic additives or agents.
  • A minority (11%) would not purchase foods with any added nutrients, even if derived from natural sources.

The results also show that 52.9% believe most vitamins and minerals are made from natural ingredients — which is not an accurate understanding. The vast majority of vitamins are synthetic.

In 2007, after the Washington Post did an article about the safety of vitamins from China, we began getting customer questions about the traceability and origins of vitamins and minerals sold in our Health and Body Care department.

Our supplements and body care merchandiser reported that 80 to 90 percent of ascorbic acid (sold as vitamin C) — as well as B vitamins — came from China. Even if a manufacturer sources vitamin C or another ingredient from, say, Europe, it's likely to be mixed with ingredients from other countries, including China.

Based on PCC's survey data, organic shoppers would be shocked and upset to know 80-90 percent of all vitamin C and vitamin B sold in the United States is synthetic. They would be shocked and upset that common vitamins originate from China; many if not most of our shoppers question the integrity of products from China and many say they do not want to buy or eat products from China.

A trade association has noted some U.S.-owned plants in China are using good manufacturing processes. Some vitamin C also is made of acerola from Brazil, but it's very pricey and much less potent. Brands such as Natural Factors, Nature's Way and Vitamer (the manufacturer of PCC's brand) do their own testing for integrity. The bottom line is that integrity depends on what the manufacturer verifies. Otherwise, there is no certainty of purity or integrity.

Consumers do not want any additives

The response to the PCC survey on synthetic additives was, in itself, significant in that it demonstrates how sensitive consumers are to having nutrients – naturally or synthetically derived – added to food products.

On the first day of the survey period, 312 questionnaires were completed online. By the second day 854 completed questionnaires were submitted. Some respondents felt compelled to respond by e-mail as well:

"Invariably the 'nutrients' added will be from the most cost effective source available, which means they will more often than not be of very low quality and effectively worthless. Even if they were of the highest quality, the practice is contrary to the concept of organic foods and has no place whatsoever on the trusted shelves of PCC Natural Markets."
— Todd H.

We interpret the data to indicate organic shoppers consider the organic foods they buy to be healthy inherently, without additives of any kind.

We conclude that organic shoppers would not support keeping the current listing, with the existing loophole, that would allow indiscriminate addition of synthetics deemed as "nutrients" to organic foods.

Organic consumers expect each additive to be reviewed and vetted, as mandated by the Organic Food Production Act (OFPA). OFPA clearly requires NOSB to review all synthetic and non-organic substances before they may be used in organic production.

OFPA prohibits use of a petitioned synthetic if it's found to be non-essential.

Since FDA does not consider any vitamins or minerals, except vitamin A, essential, they should not be allowed except by individual petition, review and approval.

Sincerely,

Trudy Bialic

Director, Public Affairs
PCC Natural Markets
Seattle, WA 98105
206-547-1222
www.pccnaturalmarkets.com

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