“Linus Pauling before Congress”*

“Linus Pauling before Congress”*

9 "Linus Pauling before Congress" * LINUS PAULING I am linus Pauling, Director of the Linus Pauling Institute, Menlo Park, California, and, since 1 A...

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9 "Linus Pauling before Congress" *

LINUS PAULING I am linus Pauling, Director of the Linus Pauling Institute, Menlo Park, California, and, since 1 August 1974, Professor Emeritus in Stanford University. For many years I was Professor of Chemistry in the California Institute of Technology, Oxford University, University of California, and Stanford University. During the past forty-three years my work has covered many fields of physics, chemistry, biology, and medicine. In 1935 I began studying the properties of hemoglobin and other proteins and the nature of serological reactions in the natural process of immunity. In 1949 my students and I published a paper on the molecular basis of the disease sickle cell anemia and formulated for the first time the concept of molecular disease. Since 1954 my research has focused on the molecular basis of mental disease, the role of vitamins in relation to both mental disease and health in general, and the development of improved methods of chemical analysis of body fluids for diagnostic and therapeutic purposes. Lhave received the Nobel Prize for Chemistry in 1954, the Nobel Peace Prize for 1962, the Phillips Medal of the American College of Physicians for contributions to internal medicine, the Thomas Addis Medal of the American Nephrosis Society, the Modern Medicine Award, the U.S. Presidential Medal for Merit for contributions to the war effort during the Second World War, and additional awards in science, medicine, and other fields. I first became aware of the value of an increased intake of vitamins in connection with my studies of schizophrenia. In 1968 I published papers entitled "Orthomolecular Psychiatric and Somatic Medicine" and "Orthomolecular Psychiatry," in which I discussed the significant role of vitamins and other natural substances in determining the mental and physical health of a person [1, 2], In 1970 I published a book entitled "Vitamin C and the Common Cold," in which evidence was presented showing that an increased intake of vitamin C leads to improved health, as shown by a decrease in the amount of illness with the common cold [3]. As a result of my studies of vitamins during the past ten years I have reached the conclusion that the proposed FDA regulations restricting the sale of vitamins would do serious damage to the health of the American people if they were to go into effect. I believe that these proposed regulations

are based upon a misunderstanding and misinterpretation of the facts about the role of the vitamins in nutrition, on the part of the Food and Drug Administration. I recommend passage of the Proxmire bill, which would restrain the Food and Drug Administration from making such recommendations. I advocate some controls over the sale and advertising of vitamins, but not through classifying them as drugs. For example, I advocate that labels should state the composition of preparations, giving, for example, the amount of rose-hip powder contained in a vitamin C tablet described as Rose-hip Vitamin C. 1. The meaning of Recommended Dietary Allowance. There is a serious misunderstanding by the FDA and most people of the meaning of the expression "Recommended Dietary Allowance (RDA)." The RDA, as formulated by the Food and Nutrition Board of the National Academy of Sciences - National Research Council, is described as being adequate for most people. This description is usually interpreted as meaning that it approximates the optimum intake for most people, that is, the intake that leads to the best of health. With this interpretation the proposed regulation classifying as drugs preparations that contain in a day's tablet more than the U.S. RDA (the U.S. RDA varies between 100 percent and 150 percent of the Food and Nutrition Board's RDA), and thus restricting their sale and use, would seem to be unobjectionable. This interpretation, however, is wrong. The RDA for a vitamin is not the allowance that leads to the best of health for most people. It is, instead, only the estimated amount that for most people would prevent death or serious illness from overt vitamin deficiency. Values of the daily intake of the various vitamins that lead to the best of health for most people may well be several times as great, for the various vitamins, as the values of the RDA. The proposed regulation restricting the sale of vitamins, through classifying them as drugs, could lead to great damage to the health of the American people, by interfering with their obtaining vitamins in the optimum amounts, such as to lead to the best of health. The FDA in making its proposed regulations about vitamins seems to have misunderstood the meaning of RDA, as formulated by the Food and Nutrition Board. The Food and Nutrition Board has stated in its reports that the RDA's are the amounts of vitamin C and other nutrients that protect against overt manifestations of scurvy and other deficiency diseases, and are not the amounts that lead to the best of health. This point has recently

* Presented before the Senate Subcommittee on Health, Sen. Edward Kennedy, Chairman. Reprinted with permission: Healthline, Volume I, #2.

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Orthomolecular Medicine

been emphasized by Dr. Harper, the Chairman of the Committee surgeons give vitamin C to patients who have been injured or are on Recommended Dietary Allowances of the Food and Nutrition undergoing operations. The extensive literature about vitamin C Board. Dr. Harper has recently [4] quoted the statement by the in relation to the healing of wounds, burns, and fractures is chairman of the first committee on RDA's that they "are not surveyed in the book on vitamin C by Irwin Stone [9]. The mechanism of the effectiveness of vitamin C in wound recommendations for the ideal diet," and also the statement of another nutritionist (Dr. Hegstedt) that the term "recommended healing is understood, at least in part. Vitamin C is required for allowance" was adopted "to avoid any implication of finality the. synthesis of collagen, the principal structural protein in the or . . . optimal requirements." body, an important constituent of bone, skin, tendon, and the There is need for further research to determine reliably the intercellular cement holding the cells of the body together. It is a part of ordinary life for most people to suffer values of the optimum daily intakes of the various vitamins. The presently existing evidence indicates that for several vitamins the occasional minor cuts, abrasions, and burns. Their healing is optimum daily intake may be two to five times the RDA, and expedited by an intake of vitamin C greater than the RDA. This that for vitamin C, in particular, the optimum daily intake for effect can be considered a part of the justification for a daily different people probably lies between five and one hundred intake greater than the RDA. times the RDA. Since most vitamins are known to have very low 4. Vitamin C and back trouble. A troublesome and rather toxicity and few side effects, even when taken in massive common complaint is back trouble, which may involve only the amounts, there is no justification for the proposed FDA regula- minor nuisance of pain in the lower back, or may develop into a tion restricting their sale in the amounts that might include the serious disease, sometimes requiring operation. Ten years ago Dr. daily intakes that lead to the best of health. James Greenwood, Jr. of Houston, Texas, reported that he Some of the evidence about the optimum daily intake of himself and many of his patients were able to alleviate and various vitamins, especially vitamin C, is summarized in the control their back trouble by an increased intake of vitamin C, following paragraphs. usually about 1000 milligrams per day (twenty times the RDA). 2. Vitamin C and the common cold. There is overwhelming In his 1964 paper [10] he reported from a study of over 500 evidence that an increased intake of vitamin C, several times the patients his conclusion that "a significant number of patients RDA (which is now 45 mg per day for an adult) provides with disc lesions were able to avoid surgery by the use of large significant protection against the common cold [3]. For example, doses of vitamin C." He found that the back pain returned when Cowan, Diehl, and Baker of the University of Michigan School of the daily intake of vitamin C was decreased, and was again Medicine reported that students who received 200 mg per day in controlled by an increased intake. Dr. Greenwood has just addition to that in their ordinary diet (probably approximately informed me (in July 1974) that his extensive added observations the RDA) had only about two thirds as much illness with the over the last ten years provided additional substantiation for his common cold (69 percent as much) as students who received an earlier conclusion that an intake of about 1000 milligrams of inactive placebo tablet [5]. The Swiss physician, Dr. G. Ritzel vitamin C per day has significant value in preventing back trouble, reported that school boys who received 1000 mg of vitamin C per as well as other manifestations of a poor state of health. His day had only one third as much illness with the common cold (37 observations accordingly support the conclusion that an intake of percent) as those who received a placebo [6]. Anderson, Reid, several hundred or 1000 milligrams per day of vitamin C may and Beaton of the University of Toronto reported a thirty approximate the optimum intake. percent decrease in respiratory illness for subjects receiving 1000 The effect of vitamin C in controlling back trouble can, of mg per day, [7] and Coulehan et al. reported thirty percent course, be attributed to its known effectiveness in strengthening decrease for older children receiving 2000 mg per day, in connective tissue by favoring the synthesis of collagen. An comparison with those receiving a placebo [8]. Several other increased strength of connective tissue should improve health in recent studies have given similar results. The evidence is over- various respects, including providing protection against ordinary whelming that a significant protective effect against this impor- complaints other than back trouble. This effect of an increased tant disease, the common cold, the cause of more illness than all intake of vitamin C accordingly provides another argument other diseases, is provided by an intake, daily, of vitamin C against the proposed FDA regulations and for the Proxmire bill. several times the RDA. 5. Vitamin C and heart disease. The most common cause of It is estimated that at the present time millions of people in death of American people is now cardiovascular disease, and its the United States are providing themselves with some protection age-specific incidence has been increasing during recent decades. against the common cold by ingesting several hundred or a few Many more young men and women die of disease of the heart and thousand milligrams of vitamin C each day. Many of these people blood vessels now than fifty or one hundred years ago. The have verified the value of an increased intake of vitamin C tendency to die of heart disease at an earlier age is an indication through their own experiences. There is no sound scientific or of poorer health. Evidence now exists strongly suggesting that an medical justification for limiting the availability of vitamin C to increased intake of vitamin C improves the health in such a way these people, in the way that would be effected by the proposed as to lead to a decreased incidence of heart disease. FDA regulations. The incidence of heart disease is higher for people with a 3. Vitamin C and the healing of wounds and burns. It is well high concentration of cholesterol in the blood than for those with known that the intake of amounts of vitamin C greater than the a lower concentration. Several investigators have shown that an RDA favors the healing of wounds and burns and the union of increase in intake of ascorbic acid leads to a decreased incidence fractured bones. The concentration of vitamin C in the blood of a of heart disease. The evidence has been reviewed recently by person who has been injured drops significantly below the normal Krumdieck and Butterworth [11]. Ginter has obtained evidence value, unless he is given extra vitamin C. Many physicians and that the mechanism of this effect is that an increased concentra-

"Linus Pauling before Congress"

tion of ascorbic acid leads to an increased rate of destruction of cholesterol by converting it to bile acids [12]. Knox has reported that people in England with a high intake of ascorbic acid have a significantly lower death rate from ischemic heart disease and cerebrovascular disease than those with a low intake of ascorbic acid [13]. Krumdieck and Butter worth in their discussion of the pathogenesis of atherosclerosis [11] conclude that "vitamin C seems to occupy a position of unique importance by virtue of its involvement in two systems: the maintenance of vascular integrity and the metabolism of cholesterol to bile acids," and suggest that it is pertinent to consider the adequacy of the present values of the RDA for vitamin C. A beneficial effect of vitamin C in relation to heart disease and cerebrovascular disease may be attributed not only to the effect of the vitamin in increasing the rate of destruction of cholesterol but also to its known effect in strengthening the blood vessels through its participation in the synthesis of connective tissue. Dr. Constance Spittle in her study in England found that a significant decrease in cholesterol concentration in the blood is achieved by an intake of 1000 milligrams of vitamin C per day. This observation provides additional evidence that the optimum intake of vitamin C, leading to increased resistance to cardiovascular disease, may be in the neighborhood of 1000 milligrams per day. 6. Vitamin C and cigarettes. It is well known that people who smoke cigarettes are, on the average, in poorer health than those who do not smoke. This poorer health is evidenced by an increased incidence of heart disease, cancer, and other diseases. The incidence of disease in general is doubled for the average cigarette smoker, leading to a decrease by eight years in the length of the period of good health and of life. It is also known that the concentration of vitamin C in the blood of cigarette smokers is less than that in the blood of non-smokers. The destruction of vitamin C by the smoking of cigarettes at the rate of one pack a day is such that a normal concentration of the vitamin in the blood can be achieved only by the ingestion of 1000 to 3000 milligrams of the vitamin per day. This intake may be considered to approximate the optimum intake for cigarette smokers. Since half of the adults in the United States smoke cigarettes, an average of one pack per day, the people who smoke cigarettes have to be considered as ordinary people, rather than patients under treatment by a physician. The proposed FDA regulations would operate to interfere with the improvement of their health by cigarette smokers through the ingestion of the amount of vitamin C needed to counteract its destruction by the cigarettes that they smoke, and would thus operate to the detriment of the health of a significant fraction of the American people. 7. Antiviral and antibacterial action of vitamin C. Many investigators have reported that vitamin C inactivates viruses in vitro (references are given in the book by Irwin Stone [9] ). The viruses that have been studied include poliomyelitis virus, vaccina virus, hoof-and-mouth virus, rabies virus, tobacco mosaic virus, and a number of bacterial viruses. Murata and Kitagawa [15] have recently reported that the inactivation results from the scission of the nucleic acid of the virus by free radicals formed during the oxidation of the vitamin C. The inactivation of viruses occurs at a significant rate for concentrations of vitamin C that can be reached in the blood with a high intake, 1000 milligrams per day, and is much less at a low intake, the RDA. Some

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protection against viral diseases (poliomyelitis, hepatitis, fever blisters, shingles, virus pneumonia, measles, chickenpox, virus encephalitis, mumps, infectious mononucleosis) has been reported by several investigators. References are given by Stone [9]. Inactivation of bacterial toxins by vitamin C and bacteriostatic and bactericidal action of the vitamin against several bacteria have also been reported, and some success in controlling various bacterial infections in man by an increased intake of the vitamin has been reported (references in Stone [9] ). The possibility that an increased intake of vitamin C has some general protective effect against both bacterial and viral diseases should not be rejected. One of the most potent defense mechanisms of the body is the destruction of invading bacterial cells by the leukocytes of the blood (phagocytosis). It has been known for thirty years that vitamin C is needed for effective phagocytic activity of leukocytes. It is also known that wounds, infections, and other stresses lead to a decrease in the leukocyte concentration of the vitamin to below the phagocytically effective level, unless the intake of the vitamin is considerably greater than the RDA. Hume and Weyers in Scotland have recently reported that in subjects who receive the ordinary intake of vitamin C the concentration in the leukocytes drops and remains below the phagocytically effective value when the subject catches cold [16]. In consequence the resistance of the person against a secondary bacterial infection is low. An intake of 200 milligrams per day is not enough to keep the concentration in the leukocytes sufficiently high, but an intake of 1000 milligrams per day plus 6000 milligrams per day for three days when a cold is contracted suffices to keep the concentration high enough to provide protection against the secondary bacterial infections that often accompany the common cold, as well as against other bacterial infections, which often are incurred under conditions of stress. 8. Animals that make their own vitamin C. Most animals manufacture ascorbic acid in the cells of their body, and do not need to have this substance, which is vitamin C, in their foods. It is unlikely that animals would synthesize more ascorbic acid than the amount corresponding to optimum health. Hence the amounts that are made by animals, two to nineteen grams per day (calculated to 70 kilograms, 154 pounds, body weight, the weight of a man) suggest that similar amounts may be near the optimum for man. The mammals that have been studied range from the mouse, weighing about 20 grams (less than one ounce), to the goat, nearly as large as a man, and the amounts manufactured are approximately proportional to body weight for these various species. The mouse has been reported to manufacture 19 grams per day, calculated to 70 kilograms body weight, and the goat 13 grams per day, on the same basis. These values provide additional evidence that the optimum intake for man is much larger than the RDA, perhaps one hundred times as large. 9. The feed of laboratory animals. The Food and Nutrition Board of the National Academy of Sciences — National Research Council formulates the values of the RDA of various vitamins for human beings. There is another committee, the Committee on Animal Nutrition of the National Academy of Sciences — National Research Council, that makes similar recommendations for domestic animals. It is my opinion that the recommendations of the Committee on Animal Nutrition are based on sounder

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evidence than those of the Food and Nutrition Board on human nutrition, because of the well known difficulties of carrying out controlled experiments with human subjects. Also, I believe that human beings are sufficiently similar in their nutritional requirements to other mammals as to justify the assumption that the optimum intakes of vitamins for animals may be applied also to human beings. Some evidence for this assumption is provided by the fact that the amounts of various vitamins (other than vitamin C) in the recommended feed of animals is not much different for different species of animals. By examining the report of the Committee on Animal Nutrition [17] I have found that the amount of vitamins contained in a day's ration of semi-purified feed (for a man, the amount with food energy 2500 kilocalories) for various vitamins other than vitamin C is usually between two and five times the corresponding RDA for man. The amounts in the recommended feed for these animals may well approximate the optimum amounts, in that many studies have been made of the composition of the feed of laboratory animals that leads to the best growth, proper reproductive capacity, and least loss through infectious disease. We might conclude that these facts indicate that the optimum intake of several vitamins (vitamin B 1} vitamin B 2 , vitamin B 6 , vitamin A) for man are in the range two to five times the respective RDA's. The guinea pig and the monkey resemble man in requiring exogenous vitamin C. The recommended purified diets for the guinea pig and the monkey contain 1100 milligrams and 1250 milligrams, respectively, of vitamin C in the ration with 2500 kilocalories of food energy, corresponding to the intake of a 70-kilogram man. These animals, which are smaller than man, eat somewhat more food, per kilogram, than man, and the daily intakes are several times greater. The values 1100 milligrams and 1250 milligrams of vitamin C per day, per 2500 kilocalories of food energy, presumably approximate the optimum intake, and may well be pertinent to man. Several studies have been made of the intake of vitamin C necessary for good health in the guinea pig. Calculated to body weight of 70 kilograms, the intake of 350 milligrams per day suffices to give good growth, 700 to prevent pathological lesions of the teeth, and 1400 milligrams per day to provide a high degree of phagocytic activity of the leukocytes to protect the animal against infection. A careful study, using several measures of good health, has been reported by Yew to indicate an optimum intake of 3500 milligrams per day (per 70 kilogram body weight) [18]. All of these studies of guinea pigs and other laboratory animals suggest that for man the optimum intake is in the range of a few grams per day, far larger than the RDA. 10. Vitamin C, menta! alertness, and general well-being. Many people have referred to an increase in mental alertness and general feeling of well-being accompanying an increased intake of vitamin C. Some have reported a failure to observe such an effect. One carefully planned and executed study about vitamin C and mental alertness is that of Kubala and Katz [19]. The subjects were school children and college women, in four schools. It was found that the average IQ was higher for the subjects with a high concentration of vitamin C in the blood serum (about 1.10 milligrams per deciliter) than for those with a low concentration. There was an increase by 3.54 IQ units in the IQ for the low group after they had received a glass of orange juice containing 90 milligrams of vitamin C every day for four months, with very little change for the subjects with high concentration of vitamin

C. Kubala and Katz suggest that the increased values of the measured IQ result from an increase in "alertness" or "awareness" caused by the improved nutritional state, and that the subjects with a low level of vitamin C in the blood were functioning at less than maximum capacity. These observations accordingly indicate that an intake of vitamin C that does not provide a blood plasma concentration greater than 1.1 milligrams per deciliter is not adequate, in that it does not permit the person to function at maximum capacity. The intake required to achieve this high concentration of vitamin C in the plasma is about three times the recommended daily allowance. A study of the general state of health of adults in relation to intake of vitamin C has been reported by Cheraskin [20]. The 1086 subjects were physicians or dentists and their wives, who were followed over a period of eight years. The number of clinical symptoms and signs of imperfect health was determined (Cornell Medical Index Health Questionnaire), and the intake of vitamin C was obtained through a seven-day survey. It was found that for each age group the number of clinical symptoms and signs decreased with increase in the intake of vitamin C. The indications of ill health were greatest for those receiving less than 100 milligrams per day, less for those receiving 100 to 200 milligrams per day, and least for those receiving 200 milligrams per day or more. There is clear indication that some improvement in health is associated with an increase in intake of vitamin C to more than 200 milligrams per day, which is more than four times the RDA. This evidence, too, supports the conclusion that the optimum intake of vitamin C is much greater than the RDA for the vitamin. 11. The low toxicity of vitamins. Vitamin C has been described as one of the least toxic substances known. People have ingested 125 grams (over a quarter of a pound) at one time without harm, and an equal amount has been injected intravenously into a human being without harm. It is unlikely that ingestion in the amounts two grams to twenty grams per day, the amounts synthesized by animals, over long periods of time would lead to harm. It has been suggested that a high intake of vitamin C continued for a long time might lead to the formation of kidney stones, but in fact not a single case has been reported in the medical literature. Physicians who have supervised hundreds of subjects who ingested four grams per day of vitamin C or more for periods of a year or more have reported that there were no serious side effects. Some ascorbic acid is converted in the body to oxalic acid, which could lead to the formation of kidney stones of the oxalate type. A careful study showed that the amount of oxalate was increased very little by an intake of four grams of vitamin C per day, and is only doubled for an intake of ten grams per day, for normal subjects. One man has been found who converts a large amount of ingested C into oxalic acid; this unusual person should, of course, refrain from ingesting large amounts of the vitamin. It is to be anticipated, of course, that because of individual variability an occasional person might not be able to tolerate a high intake of vitamin C. The number of people with such an idiosyncrasy is probably quite small. The other water-soluble vitamins are reported to be similarly innocuous, with no known lethal dose for humans. The fatsoluble vitamins, vitamin A and vitamin D, are toxic in large doses, many times the RDA. It should be required that a

"Linus Pauling before Congress" 49 statement about this toxicity be printed on labels. The toxicity of vitamin A and vitamin D have, in my opinion, been overemphasized, especially when they are advanced as an argument against the ingestion of amounts of the other vitamins larger than the RDA's. A comparison with aspirin, which is generally considered to be a rather safe drug is interesting. The number of deaths from aspirin poisoning is estimated to more than 1000 times the number from overdoses of vitamin A and vitamin D. No deaths from overdoses of any other vitamins have ever been reported. I conclude that the possible toxicity of vitamins provides no justification for the new FDA regulations. 12. Conclusion. I believe that the vitamins are important foods, and that the optimum daily intakes of vitamin C and other vitamins, leading to the best of health, are much larger than the present Recommended Dietary Allowances. I believe that the American people should not be hampered in their efforts to improve their health by an intake of vitamins approaching the optimum intake. The proposed FDA regulations would operate in a serious way to make it difficult for the American people to obtain these vitamins, by classifying them as drugs in daily amounts greater than the U.S. RDA's. I accordingly support legislation that will prevent the Food and Drug Administration from carrying out this unwise action. The values of the RDA for various vitamins have been set by the Food and Nutrition Board by consideration only of the amounts needed to prevent death or serious illness from a dietary deficiency. No serious consideration whatever has been given to the question of the optimum daily intake, the amount that leads to the best of health. In the foregoing paragraphs I have summarized the evidence for vitamin C. This evidence indicates that the optimum daily intake for human beings probably lies between about 250 milligrams per day and 10 grams per day, different for different people. It is accordingly probably between five and two hundred times the RDA for vitamin C. For other vitamins, for which less evidence is available, the optimum daily intake may be between two and five times the RDA. For several years I have taken 6000 milligrams of vitamin C each day. I take it as pure crystalline L-ascorbic acid or as 1000 milligram tablets. If the FDA regulations were to go into effect, I would be put to added trouble and expense. I might be restricted to buying tablets containing the U.S. RDA of 100 milligrams, so that I would have to swallow sixty of these tablets each day. This would mean ingesting a large amount of filler and binder in the tablets, the filler and binder constituting a larger fraction of the 100-mg tablets than of the larger tablets. Also, the small tablets are more expensive, per gram of vitamin C, than the larger tablets. An alternative would be for me to go to the trouble of getting a physician to prescribe large doses of vitamin C for me. Aside from the trouble of getting the physician to do this, I would have to pay his fee, and would also have to pay the customary higher price for prescription items. I am sure that the new regulations, if they were to go into effect, would operate to the detriment of the health of the American people. As a scientific investigator, I am interested in carrying on research on medical problems, including the problem of determining as reliably as possible the values of the optimum intakes of vitamins and other nutrients. Classification of vitamin C as a drug would in my opinion work a serious hardship on the

research effort at a time when it should be most encouraged. The regulations about research on the effects of drugs on human subjects, which in my opinion are quite proper, would operate in an unnecessarily restrictive way to hamper research in the field of nutrition, especially research on the improvement in general health of people accompanying an increased intake of various vitamins. As a consumer, I am concerned about the misrepresentations and over-pricing that have existed in connection with the sale of vitamin C and other vitamins. Even at the present time, some vitamin C preparations are being offered for sale at prices as much as one hundred times those of essentially equivalent preparations. Advertising is often misleading in suggesting a difference in vitamin C depending upon whether it contains wild rose hips or is a preparation of pure crystalline Lascorbic acid. Preparations presently available under the name Rose-hip Vitamin C may contain less than one percent of rose-hip powder, with less than one hundredth of one percent of the vitamin C coming from rose hips. The proposed FDA regulations do not in my opinion establish an effective mechanism for protecting the consumer against the abuses of misrepresentation and over-pricing. A more direct approach, I believe, lies in implementation and enforcement of strict requirements about truth in advertising and initiation of a broad-based campaign of consumer education. It should be required, for example, that the actual amounts of the various components of each vitamin C preparation be stated on the label. Requirements of this sort about truth in advertising and labeling would be extremely helpful in eliminating some of the most serious consumer abuses. I believe that the expression "Recommended Dietary Allowance" used by the Food and Nutrition Board and by the FDA is misleading, in that the RDA's are not the amounts that should be recommended as providing the best of health, but are only the amounts, probably much smaller, that prevent death or serious vitamin deficiency disease. I suggest that the name Recommended Dietary Allowance should be replaced by the name Minimum Dietary Allowance (MDA), which represents in a better way the actual significance of the amounts. I suggest also that the Food and Nutrition Board and the Food and Drug Administration should introduce a new range of quantities that might be called the Recommended Daily Intake (RDI). The RDI should be recommended as a range, corresponding to the known amount of individual variability. For vitamin C I suggest on the basis of the evidence summarized above that the RDI for an adult should be 250 milligrams to 4000 milligrams per day. Similar ranges of the RDI could be suggested for other vitamins, with values somewhat larger than the RDA's. I recommend also that the Federal government should support research to obtain more reliable information about the optimum daily intakes (RDI's) than is available at the present time. I appreciate the opportunity to address the Committee on a matter of such significance to the health and well-being of the people of the United States. Thank you.

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REFERENCES 1. Pauling, L. (1968) "Orthomolecular psychiatry," Science 160,265-211. 2. Pauling, L. (1968) "Orthomolecular somatic and psychiatric medicine,"/. Diseases of Civilization 12, 1-3. 3. Pauling, L. (1970) Vitamin C and the Common Cold (W.H. Freeman and Co., Inc., San Francisco). 4. Harper, A.E. (1974) "Official dietary allowances: those pesky RDAs," Nutrition Today 9, March-April 15-25. 5. Cowan, D,W., Diehl, H.S., and Baker, A.B. (1942) "Vitamins for the prevention of colds," /. Amer. Med. Assn. 120, 1268-1271. 6. Ritzel, G. (1961) "Kritische Beurteilung des Vitamins C als Prophylacticum und Therapeuticum der Erkaltungskrankheiten," Helv. Med. Acta 28, 63-68. 7. Anderson, T.W., Reid, D.B.W., and Beaton, G.H. (1972) "Vitamin C and the common cold: a double-blind trial," /. Canadian Med. Assn. 107, 503-508; correction 108, 133 (1973). 8. Coulehan, J.L., Reisinger, K.S., Rogers, K.D., and Bradley, D.W. (1974) "Vitamin C prophylaxis in a boarding school," The New England J. of Medicine 290, 6-10. 9. Stone, I. (1972) The Healing Factor: Vitamin C Against Disease (Grosset and Dunlap, New York, N.Y.). 10. Greenwood, J., Jr. (1964) "Optimum vitamin C intake as a factor in the preservation of disc integrity," Med. Ann. Dist. of Columbia 33, 274-276.

11. Krumdieck, C, and Butterworth, C.E., Jr. (1974) "Ascorbate-cholesterol- lechithin interactions: factors of potential importance in the pathogenesis of atherosclerosis," Am. J. Clin. Nutr. August. 12. Ginter, E. (1973) "Cholesterol: vitamin C controls its transformation to bile acids," Science 179, 702-704. 13. Knox, E.G. (1973) "Ischemic-heart-disease mortality and dietary intake of calcium," Lancet i, 1465-1468. 14. Spittle, C. (1971) "Atherosclerosis and vitamin C," Lancet ii, 1280-1281. 15. Murata, A., and Kitagawa, K. (1973) "Mechanism of inactivation of bacteriophage Ji by ascorbic acid,",4gr. Biol. Chem. 37, 1145-1151. 16. Hume, R., and Weyers, E. (1973) "Changes in leucocyte ascorbic acid during the common cold," Scot. MedJ. 18, 3-7. 17. Committee on Animal Nutrition, National Academy of Sciences - National Research Council (1962) "Nutrient requirements of domestic animals," NAS-NRC 990. 18. Yew, M.-L.S. (1973) "Recommended daily allowances for vitamin C," Proc. Nat. Acad. Sci USA 70, 969-972. 19. Kubala, A.L., and Katz, M.M. (1960) "Nutritional factors in psychological test behavior,"/. Genet. Psychol. 96, 343-352. 20. Cheraskin, E. and Ringsdorf, W.M. (1974) "Human vitamin C requirement: relation of daily intake to incidence of clinical signs and symptoms," IRCS 2, 1379.