Interview: Dr. Robert Verkerk, Executive Director of the Alliance for Natural He

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Interview: Dr. Robert Verkerk, Executive Director of the

Alliance for Natural Health.

 

Wed, 20 Apr 2005 11:20:41 +0100

 

 

 

INTERVIEW

 

 

 

DR. ROBERT VERKERK

 

Executive Director of the

 

ALLIANCE FOR NATURAL HEALTH

 

by Louise Mclean

 

 

 

 

 

The EU Food Supplements Directive became law in the European Union in

June 2002 and was later transposed into UK law in July 2003. If

unopposed, up to 5000 products could disappear from independent health

food shops across the UK after 1st August 2005.

 

 

 

The Alliance for Natural Health brought its case to the High Court of

Justice in London in January 2004 in an attempt to get this highly

restrictive Directive overturned. The hearing was successful and Mr.

Justice Richards referred the case on to the European Court.

 

 

 

The ANH's landmark challenge to the EU Food Supplements Directive was

subsequently heard in Luxembourg on 25th January 2005, with the

Advocate-General giving his Opinion on 5th April. A final ruling will

be made in June 2005.

 

 

 

Louise Mclean talked to Dr. Robert Verkerk, Executive Director of the

Alliance for Natural Health, about the EU FSD and other legislation

that will seriously impact on natural healthcare.

 

 

 

When did you first realise there would be a threat to natural

healthcare through these EU directives?

 

 

 

While I was still working with Imperial College I had a very strong

interest in the natural health area from a personal point of view. I

had signed up on the Rath Foundation petition thinking that was all I

needed to do.

 

 

 

Then a large vitamin company asked for my views on the EU Food

Supplements Directive because they had been informed by the UK Health

Food Manufacturers Association that it would not be a major problem.

This was around January 2002, just as the Directive was coming into

its second reading at the European Parliament.

 

 

 

This company had looked at the Directive and seen the so-called

Positive List of allowed vitamins and minerals and decided that there

was potentially a significant problem because of ingredients used in

their products. The list contained vitamins and minerals that would be

allowed to be sold in Europe after 1st August 2005.

 

 

 

A huge range of natural food supplements and organic forms of vitamins

and minerals had been omitted from the list which contained mainly

inorganic forms.

 

 

 

I went to the European website, downloaded the Directive and

discovered there was a dossier provision for getting nutrients onto

the Positive List if submitted before 31st July 2005.

 

 

 

I then looked at the technical requirements for these dossiers and

went to a contract laboratory to find out what it would cost to put a

dossier together for a single ingredient and got a quotation back for

£800,000! That was based on the fact that there was no pre-existing

information on the ingredient, though the cost would be significantly

less if there was some available data.

 

 

 

Although there was a campaign in existence through the Rath Foundation

and La Leva, the Italian consumer association, I felt we needed to

bring together all the groups working in this area under a unified

umbrella to work in a positive manner in the European Parliament and

try to affect the vote at second reading.

 

 

 

As it happened, I had spent many years campaigning on environmental

issues while living in Australia for 12 years. I had led campaigns

against agrochemical companies and also internationally through South

East Asia.

 

 

 

I believed we needed to employ a public affairs specialist company in

Brussels, a PR company in the UK and work around the clock for 2 weeks

to see if we could start to shift MEP opinion that was generally pro

the Directive. Within about 24 hours the campaign was born. I asked

for some time out from my job at Imperial College to take a three

month sabbatical to fight this battle.

 

 

 

 

 

If vitamins and minerals aren't on the so-called Positive List, will

they be banned?

 

 

 

Yes, unless companies can produce a dossier for each ingredient, but

the type of vitamins and minerals that are on the Positive list ignore

many food form nutrients. I could immediately see that natural mixed

carotenoids were not there, nor the natural forms of vitamin E, folic

acid or selenium. Neither were the most digestible, absorbable and

safest forms of ascorbic acid (Vitamin C) or magnesium.

 

 

 

It was very odd that the safest, most bioavailable nutrients were

missing from the list. In fact it turned out that 75% of all vitamins

and mineral forms were not there!

 

 

 

 

 

People have been greatly heartened by the Opinion released on 5th

April, of Advocate General Geelhoed of the European Court. He stated

that the Food Supplements Directive infringes the principle of

proportionality because basic principles of Community law, such as the

requirements of legal protection, of legal certainty and of sound

administration have not properly been taken into account and that it

is therefore invalid under EU law.

 

It should be stressed that the Advocate General's pronouncement is not

a ruling. That will come from the ECJ judges later - probably around

June. But typically, in the vast majority of cases, the Court Judgment

follows the recommendations of the Advocate General.

 

If the Advocate General's recommendations are adopted, in effect, the

ban on vitamin and mineral forms not included on the EU's Positive

list, due to come into effect on 1 August 2005, will be declared

illegal. In essence, the positive list of allowable nutrient forms

will be deemed to be too narrow, too restrictive, and based on flawed

science.

 

If the Advocate General's recommendations are endorsed by the ECJ

judges, it will represent the culmination of three years dogged

determination, dedication and hard work on the part of ANH and its

many supporters around the world. Advocate General Geelhoed is the

most senior Advocate General at the ECJ and his considered reasoning

vindicates ANH's legal analysis and position.

 

With rapidly declining vitamin and mineral content in fruit vegetables

and other foods, and continuing increases in degenerative diseases

such as heart disease and cancer in the West, this has always been a

very big issue worth fighting for. Fundamentally, an amended Directive

would help to slow down the agenda of the Codex Alimentarius

Commission to export worldwide an onerous, EU-style regime for food

supplements.

 

 

 

Is it true that by 2007 the EU FSD will apply to limit access to

essential fatty acids, amino acids, enzymes and probiotics, as well as

other nutrient groups?

 

 

 

Unless our case is successful, we believe that proposed restrictions

on other nutrient forms could be even more catastrophic than the

restrictions on vitamins and minerals. It is one of the absolutely

fundamental reasons why it's so important to support the work of ANH

because we are now the single biggest route in terms of creating a

positive influence because of the case we submitted to the European Court.

 

 

 

 

 

The EU FSD was passed into law without much media coverage. The wider

public weren't really aware of its existence.

 

 

 

No the public weren't really informed. This Directive had been 10

years on the drawing board with the major trade associations having

input on it. The general view in the industry was that the second

reading amendments were the best compromise that could be reached

after some ten years of discussion. We felt the Directive itself had

advantages because it was a safe harbour for food supplements outside

the medicines regime but the big killer was the Positive List.

 

 

 

We need positive media, supporting the use of natural health

ingredients because public opinion plays a role in this. If there are

hundreds of negative media articles being `manufactured' to put a

negative spin on nutritional supplements, that doesn't help us.

 

 

 

We know very well that many of these negative stories are the results

of either flawed or misrepresented studies that were conducted some

time ago and which reappear in meta-analyses. If you look closely,

you will often find that the authors themselves recognise serious

limitations but the media machines pick up these negative findings and

create headline news that `vitamins kill' based on a completely flawed

interpretation of science.

 

 

 

 

 

There is a growing body of scientific evidence that demonstrates that

the nutritional quality of the average Western diet is inadequate.

Though we in the West have never had so much available food, much of

it is deficient in nutrients. Many people are actually malnourished!

Add to this the harmful effects of pollution in the air and chemicals

in the environment. Many people who are not well are heavily reliant

on natural source micronutrients to supplement their diet.

 

 

 

There are very real problems with the modern western diet. We have

got to help the authorities differentiate between what an ideal diet

might be and what the average diet actually is.

 

 

 

I would agree that if you buy organically grown farm fresh produce and

consume large amounts of it, it would certainly be possible to eat

food that is nutritionally sufficient. However there are an

incredibly small number of people who have the time and the funds to

be able to eat diets of that sort of quality.

 

 

 

So we must look at what the average person is eating and there are

some serious issues in terms of dietary habits and dietary choices.

The reality is that our society consumes far too much simple

carbohydrate and far too few fresh fruit and vegetables.

 

 

 

For example, the National Cancer Institute in the US says that men

should consume more than 9 portions of fruit and vegetables to guard

against prostate cancer and there are other authorities that have

suggested that the requirement is upwards of 12, 13 or 14 portions a

day. It's very difficult for people to consume that amount every day.

So there are large numbers of people who are taking concentrated

sources of nutrients as nutritional supplements to make up the shortfall.

 

 

 

Interestingly, there are a number of studies showing an association

between those who spend more time in preparing their food, take more

exercise and dietary supplements and use far fewer prescription medicines.

 

 

 

The irony is that we see the regulators giving nutritional supplements

a hard time, yet it is the people who use significant numbers of high

quality supplements who are the least drain on our healthcare system.

They are often doing this in association with a number of lifestyle

factors that are keeping them healthier than the average person.

 

 

 

 

 

Saving money for the National Health Service.

 

 

 

Exactly.

 

 

 

 

 

Why do you think there is this great emphasis on safety? Do you have

any statistics of adverse effects through vitamin overdose?!

 

 

 

When you compare the adverse events profile of nutritional supplements

with foods, then compare it again with medicines, you will discover

that nutritional supplements are the safest group of products that we

put in our mouths. They are on average many hundreds of times safer

than foods and many tens of thousands of times safer than the average

medicine.

 

 

 

There have been very few adverse events associated with vitamins or

minerals. The irony is that many of the vitamin and mineral forms

that have been associated with adverse effects are actually on the

Positive List! For example ferrous sulphate, which is a form of iron

that can lead to stomach cramps, constipation or even diarrhoea, is on

the allowed List. Whereas a much safer form, iron bisglycinate, which

is widely used by practitioners, is not on the list and will be banned

from 1st August 2005 unless our court case succeeds.

 

 

 

The main problem with the existing paradigm is that it is built on a

faulty foundation around the precautionary principle. For example,

you take a nutrient group such as magnesium which is quite arbitrary.

This is because it may contain an organic form such as magnesium

gluconate or an inorganic form, such as magnesium sulphate. They are

both forms of magnesium but the sulphate form is also a form of

sulphur. So we have a relatively arbitrary categorisation of nutrient

groups.

 

 

 

 

 

Is it true that many forms of vitamins and minerals on the Positive

List will be subject to lowered potency and dosage? I believe that

the ANH is working hard to try and raise these limits.

 

 

 

The major regulatory authorities around Europe are still not convinced

of the fact that the conventional diet is substantially deficient in

nutrients and one of the problems here is that they are frequently

using the wrong yardsticks to measure sufficiency or insufficiency.

They're still widely using RDAs, sometimes referred to as Recommended

Dietary Allowances, other times referred to as Ridiculous Dietary

Arbitraries!

 

 

 

RDAs have been systematically discredited scientifically. What has

been shown very conclusively from the science is that RDAs do not have

any bearing on the safety of nutrients, nor do they have any bearing

on the amounts required for optimum health.

 

 

 

As a result, if you are using a system that primarily measures levels

of deficiency diseases such as scurvy, rickets, or beri-beri, you will

massively underestimate the extent of micronutrient insufficiency in

the population. So there is a fundamental flaw in how regulators and

so called competent authorities are interpreting the micronutrient

status of the diet.

 

 

 

The danger with any population based criteria is that it will tend to

be based on averages and one thing that is revealed about the human

condition is that there are very substantial variations, not only

between different population groups but also between individuals

within specific population groups. For example, someone who has a

malabsorption problem of a particular nutrient may need to take 50 to

100 times over the RDA of a particular vitamin or mineral to

counteract that problem. If they are able to do that, that person may

be able to enjoy perfect health.

 

 

 

When it comes to nutritional supplements that are sold in the European

marketplace, there seems to be a greater interest as we go further

north. On the whole, Southern Europeans have less interest, possibly

because their diets are naturally healthier. In northern Europe where

people find it very hard to sustain a high quality diet from fresh

produce because of the long winters, people use supplements more often.

 

 

 

You could argue that it is a natural evolutionary adaptation to

develop forms of concentrated nutrients. As an ecologist and

scientist I find it quite remarkable that here we have a piece of

legislation that actually could impede what is a completely natural

solution to the decreasing quality of our diet.

 

 

 

What you are saying is that nutrient intake is a very individual thing.

 

 

 

Nutritional supplements are in a three way squeeze. The ingredients

they contain are severely under threat through the European Food

Supplements Directive. Dosages are also severely under threat. There

is a provision in Article 5 of the Food Supplements Directive that

provides for a two stage process for which maximum levels will be decided.

 

 

 

This involves a so-called Nutrient Risk Assessment system, currently

being undertaken by a FAO/WHO Project, to determine so-called upper

safety levels and maximum permitted levels, taking into account

factors such as dietary intake and population group susceptibilities.

 

 

 

The FAO/WHO expert Committee asked for applications to assess all

these various approaches in a Workshop. Our submission has been

endorsed by a very large number of medical doctors and scientists and

was really the only one that comprehensively argued for a new paradigm

showing all the pitfalls that were associated with the existing one.

 

 

 

What the risk assessment system does is take the most toxic form of a

nutrient. It then looks at the most susceptible groups in our

population and gives you a result that is a worst case scenario. We

would like to see this radically altered.

 

 

 

It also looks at population groups that are consuming the most of this

nutrient because it takes into account dietary intake. So yes, it will

present a result that ensures that the nutrient is completely safe for

the vast majority of people in a population but it ignores the

benefits that quantities well above those dosages would have for

certain people who are deficient. The whole process does not involve

a risk/benefit analysis. It purely involves a risk analysis using a

worst case scenario precautionary principle type of approach.

 

 

 

 

 

Tell me about the EU Nutrition and Health Claims regulations.

 

 

 

Yes, the third squeeze is on what you can say about something through

the EU Nutrition and Health Claims regulations. If it goes through,

it will severely impact on what companies can say to consumers and

what practitioners can say to patients about the benefits of

supplements. It has already been knocked out of the European

Parliament once and now going through for the second time.

 

 

 

 

 

So if a practitioner were to recommend a particular product, it would

be illegal?

 

 

 

Yes. Any communication about the benefits or health claims of a

product would become illegal and also under Article 11 they will ban

any weight loss claims of any sort and any claims that refer to

behavioural changes. So for example, though we have a very

substantial problem in our society with consumption of inappropriate

foods, to say that taking Omega 3 fatty acids are good for ADHD

children, would be illegal. Yet that may be a very important and

fundamental piece of advice a practitioner needs to give to their

client or patient.

 

 

 

Unless your product is licensed as a medicine, you are not allowed to

talk about its benefits, even if it is a food. We believe that

there's a reasonable chance that the Nutrition and Health Claims

regulations could also be illegal under European Law.

 

 

 

 

 

It would severely hamper the work of nutritionalists and other therapists.

 

 

 

We believe that it could represent a very severe infringement of

freedom of speech because it will prevent people talking about the

true benefits of a range of products.

 

 

 

In terms of coming back to doses, there's a very real possibility that

the sort of dosages that are regularly used safely by nutritional

therapists will be made illegal, unless the scientific process for

determination of maximum doses is radically reformed.

 

 

 

Under the EU Nutrition and Health Claims regulations, even if you have

scientific evidence of the role of a particular nutrient, you cannot

state it, unless that nutrient has gone through a formal process of

substantiation. This involves costs, with manufacturers having to put

their data to the regulators in Europe and then having it approved.

It might not be approved, simply because the manufacturer hadn't got

enough money to collate the data for the Health Claims procedure. So

then you can no longer state the health benefits of your product.

 

 

 

The burden of proof is being put back heavily on companies. Only the

big companies have sufficient funds to get through the door. If you

are a smaller company and can't afford to get your ingredient through

a dossier or get your health claim through the pass claims procedure,

you are not allowed to use the ingredient and you're not allowed to

promote it because it hasn't been approved. So it is a classic case

of big business wins every time.

 

 

 

If you look at the whole marketplace for nutritional supplements

today, there is no doubt that the supermarkets represent the bottom

end and nutritional therapists represent the most developed end of

that market and therefore they would have their toolboxes destroyed

more or less completely.

 

 

 

 

 

Do you think the pharmaceutical companies want to take over this

lucrative market?

 

 

 

There are a number of vitamin companies that have been bought up by

pharmaceutical companies. The most well known example is that of

Wyeth buying up Solgar and Lamberts being bought by Merck.

 

 

 

The pharmaceutical companies are currently responsible for the supply

of some 70% of raw vitamin and mineral ingredients used across Europe

so they are heavily involved in the market already. There is

undoubtedly an interest from their part to see what they would

consider a level playing field. They are asked when they supply drugs

to fulfil very detailed studies on both efficacy and safety to get a

drug to market.

 

 

 

So they're saying right, if vitamins and minerals and other nutrients

are to be used for healthcare purposes, should they not go through the

same regime? They say yes and we say no. Just as we would expect to go

to our local market and buy broccoli and carrots without those being

tested because they've been part of our food supply for hundreds of

years.

 

 

 

 

 

Is it possible that in time the only way people will be able to obtain

vitamins will be through their doctor by prescription?

 

 

 

No, vitamins would always be available. The problem with the European

legislation is that the market for food supplements would be a very

limited range of products. These would inevitably be `me too' products

and the supermarkets and pharmacies would control that market.

Suddenly there would be no ability for practitioners or independent

retailers to supply products that were different and as a result they

would not be able to compete.

 

 

 

It will be drug companies who will be able to manage a Food

Supplements Directive regime in a cost efficient manner. So the

likelihood is that over time they may be the sole players left in the

marketplace but they would make low dose, narrow spectrum products.

 

 

 

 

 

Can you explain the purpose of the Codex Alimentarius Commission

meetings that have been held over the past few years? Will these

guidelines have to be adopted by countries worldwide?

 

 

 

Codex Alimentarius is a food code. The United Nations developed the

guidelines for its 160 or so member countries. Some 10 years ago it

turned its attention to vitamins and minerals.

 

 

 

The reality is that Codex is following a very close parallel to the EU

Food Supplements Directive. In fact the primary concern of Codex in

relation to vitamins and minerals, are dosages. The proposed way

forward is identical to that which is included in Article 5 of the

Food Supplements Directive. It has all the same problems associated

with it.

 

 

 

If it goes through in the current state it will be based on deeply

irrational and flawed science and we'll end up producing guidelines

that are far too low for many vitamins and minerals. In the future

that flawed science will be applied to other categories of nutrients

as well.

 

 

 

There is considerable debate about the effects of the guidelines and

whether they are binding. In order for a country to remain

competitive it would be very likely to follow the guidelines, even

though it may not be compulsory for them to do so. Under the process

of global harmonisation and through the World Trade Organisation, many

countries would end up following the guidelines irrespective of

whether it was compulsory to do so.

 

 

 

The whole Codex process is very much under discussion. The text was

finalised in November last year but the biggest area open to

negotiation now, is the risk assessment process which we are very

heavily involved in. The guidelines will be ratified at a meeting in

Rome in July this year.

 

 

 

We need a combination of heavyweight scientists behind a new paradigm

as well as getting as many countries as possible behind our message.

We have become aware that the countries able to understand the

problems with risk assessment, are those not necessarily linked to

major commercial producers interested in low dosages. These include

many developing countries. We are working with a number of key

countries at the moment in order to try and stimulate a snowball effect.

 

 

 

Regulatory and industry pressure through the EU Food Supplements

Directive was always likely to translate globally, particularly to the

US, through Codex and the World Health Organisation.

 

 

 

 

 

There are two other EU Directives that are causing concern among

natural health practitioners and companies. I believe you are working

hard to push for amendments. One is the Human Medicinal Products

Directive and the other the Traditional Herbal Medicinal Products

Directive.

 

 

 

There are a number of pieces of other EU regulation that could pose

very serious problems for natural health practitioners. One of them

is the Human Medicinal Products or Pharmaceuticals Directive which

passed into European Law in 2004 and is presently being transposed

into Swedish member state law. We are following this very closely.

 

 

 

In a nutshell it has got two major problems. It is designed to

control pharmaceutical products but has such a wide definition, it can

affect virtually any product it chooses. The definition basically

includes any substance or combination of substances used to correct,

modify or restore physiological functions of the body. It is so broad

that even foods fit this category.

 

 

 

The second aspect of the Human Medicinal Products Directive is that it

has a provision that allows it to trump any other piece of European

Law. If for example something fits as a food supplement, it would

also fit as being a drug under this Directive. So that gives the

regulators a big gun to more or less choose at will whatever product

they want and call it a drug.

 

 

 

Sweeping powers

 

 

 

Yes, and we're beginning to see a number of natural products already

being classified as drugs. Glucosamine, which is used very widely by

people to manage arthritis, has already been reclassified as a drug in

both Sweden and Denmark.

 

 

 

Because this Directive has already passed into European law, it must

be challenged through the Courts. We put through a number of

significant amendments to the Human Medicinal Products Directive

during the first reading but those were all lost in a compromise

package that was put together at the last minute.

 

 

 

So we have a paper trail of very positive work. We also know the

European Parliament was very supportive of the amendments that we

tried to put through and we now say that the law is a bad one,

particularly as it relates to natural products. We are presently

investigating mechanisms for bringing a legal challenge against it.

 

 

 

The Traditional Herbal Medicinal Products Directive is due to come

into effect in the UK on 30th October, 2005. It is a subset of the

Pharmaceutical Directive and it is only regulating what are termed

medicinal herbs. There's a real question mark as to what you consider

to be a herb that's medicinal because it still needs to comply with

that very erroneous definition of a medicine. So if the regulators

believe a plant extract is medicinal, it allows them to say that

you've got to go through a drugs licence procedure if you want to

bring it to market.

 

 

 

The THMPD is like a fast track for a medicinal licensing system. It

simply says that if you can prove 30 years safe use, of which 15 years

is in an EU member state, we will allow you through the door without

submitting all the safety data to us.

 

 

 

 

 

So Bach flower remedies would get through?

 

 

 

Yes, but what it will impact particularly badly on is non-EU

traditional medicinal regimes, for example Ayurvedic medicine.

 

 

 

Essentially what the system is saying is that a free randomised

placebo controlled study is of much greater value than several

thousand years of development of a traditional medicinal culture.

 

 

 

 

 

Tell me about your background and how you came to be working in this

field?

 

 

 

My background is first and foremost as an ecologist. I took a degree

in ecology between 1978 and 1981 because I've always been concerned

about the state of the planet. One of my key concerns has been

sustainability of the natural environment. I spent some 10 years with

Imperial College, London, working in the field of sustainable

agriculture and did two degrees there, a Masters degree and a PHD.

Then I worked as a post-doctoral research Fellow.

 

 

 

My key interest has been looking at interactions within agricultural

systems, between plants or crops and herbivorous insects (that people

refer to sometimes erroneously as pests).

 

 

 

Natural systems are complex. The more we manipulate agricultural

systems the more we start to confuse the balance of nature. In a

natural environment, there is a balance between different trophic

levels. When we look at an agricultural system, many people believe

the only way you can stop plants and crops being defoliated or ravaged

by pests, is to put pesticides into that environment to try and

regulate it.

 

 

 

I started to appreciate that there are real similarities between the

external environment and the internal human environment. There is a

real analogy between people being interested in sustainable

agriculture and people interested in natural health.

 

 

 

Those interested in natural health are trying to find a natural

balance within their bodies, just as those interested in organic

agriculture are not going to put toxins into their agricultural

environment.

 

 

 

Pharmaceutical drugs are analogous to pesticides. You put them into

your body and they create an imbalance. The body responds in many

different ways to try and deal with toxins introduced and the reality

is that it's not sustainable.

 

 

 

Just as conventional agriculture is not sustainable, orthodox medicine

is not sustainable. We know that just by looking at the statistics of

the side effects of drugs. We have more than enough indicators to

suggest that we cannot continue with the so called orthodox healthcare

paradigm, where people are living their lives yet are not sufficiently

in control of taking responsibility for their health.

 

 

 

The other thing that drew my interest to natural healthcare was the

understanding that nutrient quality in agricultural systems is vital.

The more you look at conventional agricultural systems, the more you

recognise that the quality of foods we eat today is extremely inferior

to those we have eaten and evolved with over thousands of years.

 

 

 

This is not just because we are eating a lot of hydroponically

produced foods or sowing crops in land that has been depleted of

minerals. It is because the actual crop cultivators today are

genetically and in every other way, very, very different from the

foods with which we have evolved.

 

 

 

So it's no great surprise to me that we have large numbers of people

with wheat allergies and food allergies generally. It's quite simply

that our bodies have not adjusted to the foods available today. Those

are the primary factors that drew me into this area.

 

 

 

 

 

For further information and to make urgent donations towards the work

of the Alliance for Natural Health, please see their website at

www.alliance-natural-health.org

 

The ANH is a not for profit NGO. It is a pan-European, international

alliance of scientists, natural healthcare companies, healthcare

practitioners and consumers working to protect the long term interests

and sustainability of natural healthcare.

 

 

 

About the Author: Louise Mclean is a qualified homeopath and editor

of Zeus Information Service, campaigning to protect access to natural

health therapies and products. www.zeusinfoservice.com To

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