Correspondence

Raw Animal Tissues and Dietary Supplements

N Engl J Med 2000; 343:304-305July 27, 2000

Article

To the Editor:

Although dietary supplements are often called “herbal supplements,”1 they may contain raw animal parts. The label of one nationally distributed product lists as ingredients 17 bovine organs, including brain, spleen, lung, liver, pancreas, pituitary, pineal gland, adrenal glands, lymph node, placenta, prostate, heart, kidney, intestine, and thyroid. Labels are rarely this forthright but instead often obscure the fact that animal tissues are present. For example, a bull's testicle is usually called “orchis,” which may mislead the etymologically impaired. Product names may also confound; a jar labeled “thymus” may contain either the herb thyme or bovine lymphoid tissue. Some products contain so many ingredients that the print on the labels is almost unreadably small, which may serve to hide the presence of the offal within.

Do we have adequate regulations to protect the American public from the possibility that the animal products in dietary supplements are contaminated? I believe that we do not, largely because the Dietary Supplement and Health Education Act of 1994 limits federal authority to regulate dietary supplements.

For example, the Department of Agriculture considers most bovine organs found in dietary supplements to be susceptible to contamination with the agents of bovine spongiform encephalopathy.2 But the Department of Agriculture's ban on the importation of these tissues from countries in which the disease is found among cattle2 applies only if the tissues are intended for use in food, medical products, and medical devices, not if they are intended for use in dietary supplements.

A recent study on the transmission of prion diseases in mice suggests a causal relation between the consumption of meat from animals with bovine spongiform encephalopathy and the new-variant Creutzfeldt–Jakob disease.3 Yet the Dietary Supplement and Health Education Act allows the Food and Drug Administration simply to recommend the exclusion of high-risk animal tissues from dietary supplements; it does not allow their prohibition.2 Accordingly, the health food industry has no restrictions on the source of animal tissues used in their products. Earlier this year, a court-ordered reinterpretation of the Dietary Supplement and Health Education Act further weakened the ability of health officials to oversee dietary supplements.1,4

Consumers who are wary of “mad cow disease” might want the labels of dietary supplements to provide understandable taxonomic, anatomical, and geographic information about any animal parts listed. Vegetarians, persons who have religious restrictions regarding the consumption of meat, and those who find kibbled cow repugnant will also value this information.

William Osler described medieval medicines as containing “scores of substances, the parts or products of animals, some harmless, others salutary, others again useless and disgusting.”5 To describe modern dietary supplements, should we add “dangerous” to Osler's description?

Scott A. Norton, M.D., M.P.H.
6714 Georgia St., Chevy Chase, MD 20815

5 References

1. 1

   Gottlieb S. US relaxes its guidelines on herbal supplements. BMJ 2000;320:207-207
   CrossRef | Web of Science | Medline

2. 2

   Detention without physical examination of bulk shipments of high-risk tissue from BSE-countries. Import alert #17-04. Department of Agriculture, revised 24 January 2000.
   

3. 3

   Scott MR, Will R, Ironside J, et al. Compelling transgenetic evidence for transmission of bovine spongiform encephalopathy prions to humans. Proc Natl Acad Sci U S A 1999;96:15137-15142
   CrossRef | Web of Science | Medline

4. 4

   Regulations on statements made for dietary supplements concerning the effect of the product on the structure or function of the body: final ruleFed Regist 2000;65:999-1050
   

5. 5

   Osler W. The evolution of modern medicine. New Haven: Yale University Press, 1923:118.
   

Citing Articles (2)

Citing Articles

1. 1

   Christopher E. Beisel, David M. Morens. (2004) Variant Creutzfeldt‐Jakob Disease and the Acquired and Transmissible Spongiform Encephalopathies. Clinical Infectious Diseases 38:5, 697-704
   CrossRef

2. 2

   Roos, Raymond P., . (2001) Controlling New Prion Diseases. New England Journal of Medicine 344:20, 1548-1551
   Full Text