Prepared testimony of Roger J. Williams, Ph.D., D.Sc., August 14, 1974

[Accompanying oral statement]

The cell is the fundamental unit of all life and metabolism is what happens within living cells. We human beings could not exhibit living characteristics if our bodies were not coordinated systems of living, metabolizing cells.

Nutrients and drugs both affect metabolism, but they do this in entirely different ways. Nutrients furnish the materials from which metabolic machinery is built; drugs interfere with parts of the metabolic process. Life can exist in the absence of drugs but without nutrients, life is impossible.

Living cells have in them complex machinery (metabolic machinery) consisting essentially of structurally coordinated systems of thousands of chemical catalysts. This metabolic machinery must be built within the cells and the nutrients are the source of the essential chemical building blocks—minerals, trace minerals, amino acids and vitamins—for building this machinery.

Drugs, on the other hand, furnish nothing constructive; they interfere with parts of the metabolic mechanisms and by blocking certain phases of the operation, they alter the course of metabolism. This may, directly or indirectly, bring temporary benefit. No drug furnishes an essential building block. An agent which does this is a nutrient, not a drug.

Since drugs and nutrients affect metabolism in entirely different ways they cannot be considered as equivalent; any proposed regulations which would aptly apply to drugs would be inappropriate for nutrients and vice versa. If the sale of both drugs and nutrients are to be regulated governmentally, they must be dealt with separately. No one would think of putting cereal grains and insecticides in the same category and formulating blanket rules that would cover both, even though they are both agriculture-related, may be granular in form, and put up in bags.

The cause of the confusion lies in the fact that sometimes nutrients and drugs appear outwardly and superficially to act alike. Thus on the one hand an antibiotic, a drug, may greatly relieve an infectious disease; on the other hand, vitamin B₁, a nutrient, will greatly relieve beriberi. This action of vitamin B_l is not at all typical of nutrients as a group, however, and the mode of action is very different from that of a drug. The antibiotic interferes with metabolism, particularly in the parasitic organism, and tends to nullify the action of the invading parasite. Vitamin B₁, on the other hand, builds up the metabolism of the individual treated, by furnishing a material needed to construct their metabolic machinery.

There are approximately 40 individual essential nutrients: Minerals, trace minerals, amino acids and vitamins. Of these very few indeed act as remedies for diseases. The few which can counteract a disease by themselves affect only diseases that, practically speaking, we do not encounter in the U.S.A. Together, however, working in cooperation all nutrients, acting as a team, make life and health possible.

An illustration of how proposed regulations which may aptly apply to drugs are entirely inappropriate for nutrients is as follows: It is proposed quite appropriately, that drugs, in order to be sold, should be judged safe and efficacious. Nutrients, in general are far safer than drugs so no hardship would result from using safeness as a criterion for the sale of nutrients. However, as we have indicated, nutrients as a group are not medicinal agents which cure diseases. They are not efficacious by themselves, the way acceptable drugs are. Nutrients always act constructively and cooperatively and their sale should be regulated only on this basis. If the proposed regulations with respect to drugs were to be enforced with respect to nutrients, at least 90 per cent of the nutrients could not be sold at all, because tested as drugs are, they are not efficacious. Working together cooperatively, however, nutrients are absolutely essential to life and health.

Drugs and nutrients are not the same. It is of great scientific and biochemical importance that they be differentiated. No legal pronouncements even if repeated a thousand times can make drugs and nutrients the same. They simply do not belong in the same category.