Vitamin D

Making Clean Vitamin D

The pollution problem for vitamin D comes from the need to dilute it to the standard 400 units allowed by regulations, in such a way that the consumer knows how much they are getting. This can be done in an elaborate way or a simple way such as adding it to plain oil with flavor added. But oil is never “plain”. It comes polluted with PCB, benzene and often antimony, an outright poison. It also is loaded with Ascaris eggs and other invisible filth. The flavoring is not simple either. It might have any or all the immune-destroyers. Both oil and flavoring must be tested. Fortunately, electronic testing is right through the container so it can be returned if not satisfactory. PCB, benzene and Ascaris eggs can be zappicated, zapped or sonicated out, but antimony remains antimony. The product must be returned for this contaminant.

If you are a small business, trying to get started, you could not spend your first dollars on finding a lab that could test oil for antimony. So you think, surely the FDA could help or advise me where to turn for help. They respond courteously but say they have never heard of antimony in olive oil, that they do not do such testing themselves, know of no labs that do this and are sorry they cannot help.

But antimony is a strong poison; it is regulated out of (tested for) the public water supply. Does this mean our foods could have subtle poisons in them without anybody finding out about it, including the FDA in whom we have come to trust?

With nowhere to turn, your enterprise is stalled. You may be tempted to quit or tell yourself: maybe a little antimony isn’t so bad—nobody seems to be dying from it—maybe it’s all overrated, so I will carry on. Or you send several samples to a friend who knows a Syncrometer® tester, so you can pick the clean one.

The vitamin D3 concentrate, as it comes from the manufacturer could have lead in it. This cannot be easily fixed either, it must be returned. The Syncrometer® tester could find this out for you too. Lead could come simply from the copper plumbing used in the manufacturing plant.

So you see how pollution and contamination at the very beginning of the preparation of a supplement could get amplified into a formidable problem at the end. The final product will carry every pollutant brought in from all the ingredients.

Without the help of testing labs or a Syncrometer® tester my advice would be to put a very small amount of EDTA in the product to chelate any lead or other heavy metal, even including antimony. The amount allowed in food could be found in the Federal Register. And it should be stated on the label.

For small batches the flavoring and vitamin D3 concentrate could be added by dropper to a large bottle of diluting oil that could be closed and shaken mechanically or even by hand. But for large batches they would need to be mixed in a mixing vat with paddles driven around by a motor. Now it is a very quick procedure. But how to clean it all up? The same vat needs to be used for another product next day. Your business adviser tells you that only a solvent like benzene, xylene or toluene (like Solvex or Solvall, an imaginary name) could do a “good” job in a reasonable time. The drainings can be saved for future cleanings. A second washing in “non-toxic” food-contact-acceptable solvents (like Foodsafe, another imaginary name) gives a second batch of drainings to be used again for the same purpose. Solvents are quite expensive. A list of food-admissible solvents is given in the Federal Register. Reading these and remembering your business “advice”, you instinctively know this is not how your mother would clean up dishes! There is something very wrong. You check into some safer and simpler cleaning methods. But your business adviser, the maker of the mixing vat warns you…

If different or cheaper solvents are used, a lacquer may build up on the paddles. An odor or taint may develop. Mold and bacteria could become a problem. The machines dare not use anything except what is specified for that machine, or lose the warranty on it as well as getting bad results.

Maintenance of complex machinery is taken care of by the company that makes it, so this company does not want any interference with its own solvent solutions, or cleaning schedules. The machine supplier does not want to get repair bills for its mixing vat, or to pay for extra maintenance under the warranty, nor to have the machine returned to them, nor to lose a customer!

We must see the problem in all its complexity.

You, the young new manufacturer could conclude not to change anything, not to tamper with anything, and as long as laws are obeyed or gotten by, there is no necessity to change anyway! Manufacturers are stuck and we must understand this. There is a huge investment in very expensive machinery and this cannot be jeopardized.

As such equipment gets introduced to developing countries, they, too, will be locked into a production method that cannot be changed.

Or you, the new entrepreneur, could decide to stay small and forgo the big automated equipment. You can shake the bottle by hand or adapt a paint mixer or invent your own machinery.

This is the opportunity for the small manufacturer to get into the market by making cleaner products. There is a growing demand for real health foods and real supplements.

By switching to ethyl alcohol for washing away oils, steam to clean utensils, iodine (Lugol’s) to disinfect, heat to make it all more efficient (though dangerous) the new cleaner products could easily stand the scrutiny of any Syncrometer® tester or the finest testing lab. The small manufacturer could display the results proudly.

By switching to registered hypochlorite solids, instead of supermarket laundry grade bleach for sterilizing equipment, azo dyes and lanthanides disappear along with a host of other heavy metals.

By using plain tap water instead of reverse osmosis, thulium and ytterbium disappear from the product.

By changing battered old copper pipes with corroding lead solder joints to PVC with brass fittings the lead and copper are likely to be gone from the product.

After these changes the expense of a test, done by a modern analytical lab, sensitive to parts per trillion for most items could pay for itself. A resounding ND (not detected) for all five immune lowering pollutants would certainly attract customers, especially if results are displayed.

As the sales accounts move toward small manufacturers, the makers of the big name products may or may not take notice. The big manufacturer may prefer the “quick fix”: to demolish the competition, sue the complaining public, even the labs, and write new laws allowing all these pollutants. The big manufacturer would not even know, nor care to know, why accounts are being lost, as long as he/she could fix it in the usual quick fix (lawsuit) way. They would certainly not blame the equipment makers. They would perceive the complainers (such as you and I) as troublemakers to be silenced, or zealots to be ridiculed.

And if the FDA or other regulators ever demanded a better report for the final manufactured product, or the manufacturer was, finally, trying to learn the pollution problem, the equipment makers would still not come under scrutiny. The equipment makers are part of the fabric, the very flesh and bone of manufacturing. Without them, we are back to feudal times. It will be much easier to blame the FDA for over regulation and to try to pull some tough strings with them for a more liberal (to them) position than to correct the equipment problem.

We must understand the FDA and EPA problems, too. They too, struggle to reach solutions that satisfy everyone.

Ultimately, competition is the toughest teacher. As large companies lose business and small companies grow, these new ones will be tempted to use the same ways to avoid change: to denounce all complainers and to destroy the competitors without regard for society’s welfare.

Again, it must be we (the people), who are using a Syncrometer®, who must distinguish polluted from clean products. It is only this new technology that can forge a path in commerce to truly benefit you and the rest of society. It is important to learn to use it, even though it is still manually operated. Train yourself.

Dr. Clark's Home Page