By Rufus Greenbaum, with ANH-Intl

Public Health England recently published its Scientific Advisory Committee on Nutrition (SACN) “Draft Vitamin D and Health Report”, which is currently open for consultation until 23rd September 2015. It’s 8 years since the last report was released in 2007, and during that time there’s been a wealth of evidence published, on the benefits and importance of adequate vitamin D levels for good health. So it’s disappointing, but not overly surprising, that SACN have effectively made no recommendations for health policy changes in the key areas of what independent experts would consider adequate serum vitamin D levels. Recognition of the importance of adequate levels for the prevention and treatment of multiple diseases also appears to be somewhat lacking. In addition, we note that there are no changes in sun exposure recommendations.

ANH-Intl will submit detailed comments to the consultation in September. In the meantime, ANH supporter and informed health policy stakeholder, Rufus Greenbaum, has provided us with a summary of his considered comments. Mr Greenbaum is one of the few people to have attended and observed most of the meetings of the Scientific Advisory Committee on Nutrition, starting in 2009 when he made his first submission to the committee.

When “magic bullet” thinking distorts reality

When the British Medical Journal published an editorial in April 2014 dismissing the health benefits of vitamin D supplementation, the stage was perhaps set for future government policy. The article was ominously headed “Multiple meta-analyses but still no magic bullet”, and ANH-Intl highlighted its view at the time that the problem lay less with vitamin D than with mainstream medical thinking and the randomised control trial itself.

A strong evidence base suggests that people with low serum vitamin D levels [less than 75 nmol/L (30 ng/ml)] are more at risk of immune suppression, cancer (required levels are higher at 90–120 nmol/L (36–48 ng/mL)], depression, fracture risk/osteoporosis, other chronic diseases and all-cause mortality. The SACN Draft Vitamin D and Health Report falls seriously short of this in its serum 25(OH)D concentration recommendations below which deficiency can be diagnosed. The UK government health ‘no change’ policy is a cop out.

Policy should also require much wider testing of vitamin D serum levels, for a wider array of symptoms presented by patients. In addition doctors need to be equipped to offer more effective advice about adequate sunlight exposure and vitamin D supplementation. These are accessible risk reduction methods.

The DOH vitamin D advice

The Department of Health has 2 primary sources of official advice about Vitamin D, which are the UK National Institute for Health and Care Excellence (NICE) and the Scientific Advisory Committee on Nutrition (SACN). The SACN last issued a report on Vitamin D in 2007 and has spent 4 years drafting an update, which they have just issued for consultation by September 23.

Pros and cons

The main positive is that the government has finally accepted that everyone in the UK needs Vitamin D. This means that everyone involved with our health will have to take some action, even if they only advise us to take a supplement which we buy ourselves.

The primary negative is that the official definition of Deficiency has not been changed and stays at a Vitamin D level of 25 nmol/L. So your doctor will not have to take any formal action, since most people are above this level for most of the year. This is almost certainly a political decision, since it was announced very early in the programme, and it means that the Department of Health will not have to pay for extra treatment.

The average light-skin person varies between 35-75 nmol/L during the year and people with dark skin are much lower. Many health conditions, like Depression and Flu, vary throughout the year and this can be traced to lack of sunlight – which affects our Vitamin D level.

The second negative is that the SACN did not look hard enough to find evidence that higher levels of Vitamin D are good for us. The USA definition of deficiency is set at 50 nmol/L, while there is good evidence that our bones need 75nmol/L all through our life. In addition, a group of experts have issued a “Call-To-Action” to say that we need to set a target of 100-150 nmol because:

“There are newly appreciated associations between vitamin D insufficiency and many other diseases, including tuberculosis, psoriasis, multiple sclerosis, inflammatory bowel disease, type-1 diabetes, high blood pressure, increased heart failure, myopathy, breast and other cancers which are believed to be linked to the non-calcemic actions of the parent vitamin D and its daughter steroid hormone”.

Lack of evidence, or is there…

The SACN spent 4 years reviewing 8 major heath groups and could not find evidence as rigorous as that needed from drug trials. One hour reviewing could have shown them where Randomised Controlled Trials have been done that shows that higher levels of Vitamin D can both prevent and treat more than 50 illnesses.

So you are invited to review the draft report and submit your comments, alongside ANH-Intl and many other stakeholders, by September 23. As you read each section of the SACN report go to and make your own comparisons. It makes for interesting and informative reading if nothing else!

Maintaining the status quo and protecting vested interests?

So they don't want the level of deficiency raised — and they don't want any new illnesses specified that require treatment! A cynical person might suggest that this report is politically biased. There are many who would agree, and who recognise that governments and health authorities drag their feet over treatment protocols involving supplements and common sense diet and lifestyle interventions. Many acknowledge that protecting big pharma’s bottom line is a significant factor in this. This is a huge injustice to people and patients, and it is unacceptable that so many suffer as a consequence. As ANH has said before “Without drastic change, rates of chronic disease – largely unmanageable pharmaceutically – are destined to continue to soar”.

About Rufus Greenbaum

One of the few people to have attended and observed most of the meetings of the Scientific Advisory Committee on Nutrition, starting in 2009 when he made his first submission to the committee. Mr Greenbaum is also listed as a Registered Stakeholder with the UK National Institute for Health and Care Excellence (NICE) and submits comments for many illnesses where vitamin D, omega-3 and other vitamins, minerals and food/dietary supplements may be relevant and useful to prevent or treat the illness.

You can see more of his interests and work at: