Dr. John Vanderveen
Director, Office of Plant & Dairy Foods & Beverages
Food & Drug Administration
200 C St., SW
Washington, DC 20204
Dear Dr. Vanderveen:
In response to your letter of Oct. 4, 1995, about 643 days have elapsed since I sent my paper, "Calculations of American Deaths Caused By Magnesium Deficiency..." to Dr. Troxell in Jan. 1994. Based on those calculations of about 590 deaths per day, about 379,000 deaths from magnesium deficiency have occurred since Jan. '94. Apparently $400,000 has been budgeted by the FDA, NIH, and NAS for two small magnesium studies, which would be barely $1 per death, and even those studies seem rather marginal and not entirely to the point. What is needed is a large intervention study, preferably using Mg in water, since Mg in water is 30% more bio-available than Mg in food or pill, as referenced in Petition 94P-0361/CP1. Mg-enriched beverages are the only practical way of conveying uniform dosages of Mg to the public, as intake of particular foods such as bread varies widely from individual to individual, but intake of water-based beverages is relatively uniform.
You have stated, "We recognize that dietary intake studies indicate that many individuals are consuming significantly less than the RDA for magnesium". Thirty years of research have indicated that magnesium deficiency is a cause of heart disease. You also state that "Scientific experts do not support (a public health emergency) in this case." Who are these anonymous scientific "experts"? They must not have read the literature. Mg-deficiency obviously constitutes a Public Health Emergency.
You further state, "The large majority of waters... contain minerals of little nutritional significance". Dr. Neutra noted in his literature review that "many of the cardio-protective effects resulted from surprisingly low levels of water-borne magnesium." So your statement is blatantly false.
You further state, "The agency does not normally view water as a significant nutrient source." This is a self-fulfilling statement, since American bottled waters average 2.7 mg/L magnesium, and the rest of the world's bottled waters average 28 mg/L -- more than 10 times as much magnesium! (A list of the mineral content of all the major bottled waters of the world is attached, with references to source books.) If a consumer drinks 2 liters of water per day, containing 56 mg magnesium, and if that 56 mg is 30% more bio-available than Mg in food, it is equivalent to 73 mg of magnesium in food, which is hardly insignificant.
How did this catastrophe happen? As near as I can tell, what happened was that many American doctors were envious of the popularity of "healing waters", and so convinced the FDA and its predecessors to smear the reputation of water-borne minerals and practitioners using water-borne minerals. Also, for over 100 years European communist intellectuals were known for drinking mineral waters, so the anti-communists in America made "pure water" a rallying cry to besmirch the mineral-drinking leftists. In American fiction, the pure-water-drinking-right-winger is a stereotype. Joe Mc Carthy wouldn't have been caught dead drinking a mineral water.
Your statement that "The Agency does not normally view water as a significant source of minerals" is thus a silly anachronism, and totally out of line with the rest of the world. You have absolutely no scientific evidence to support your position, so change it before you kill millions more. Declare a National Health Emergency.
cc: Dr. Terry Troxell
Dr. Floyd Horn
Dr. Claude Lenfant
Dr. Mildred Seelig
Dr. Raymond Neutra
Dr. Allison Yates
Dr. Atsutane Ohta
encl: Global list of mineral contents of bottled waters.
This page was first uploaded to The Magnesium Web Site on November 16, 1995