FDA Crackdown on Vitamin D Fortification is Troubling

G. Douglas Andersen, DC, DACBSP, CCN

Volume 21, number 20, 9/24/03, page 17
Includes discussion on how we make vitamin D and the risk factors for deficiency and the recent decision to remove it form many vitamin fortified protein bars and powders.

A few months ago I noticed vitamin D was removed from my vitamin- and mineral-enriched protein powder. Since I tend to be a label reader, when I started looking at other brands, I noticed that they, too, began to remove vitamin D. I also noticed this in many of the protein and carbohydrate bars in the health food store. I called the manufacturer to ask why they eliminated vitamin D from their product, and was told that the government forced them to do so.

On April 1, 2003, the Revised Code of Federal Regulations was released. In Title 21, volume 3, part 184, subpart B, section 184.1950, vitamin D is discussed. In that section, the law states that only the following foods may be fortified with vitamin D.

  • Milk and milk products
  • Breakfast cereals
  • Grain products and pastas
  • Infant formulas
  • Margarines

    The restrictions on vitamin D fortification to food are troubling due to the fact that there is less vitamin D in foods than any other vitamin. The best sources are fatty fish. Vitamin D is also found in egg yolks, butter, cream, and liver. Of the food groups where fortification is allowed, only milk (100 IU/8 oz – 25% US RDA) is a significant source.

    In many western countries, including the United States, populations are aging. In the US, consumption of milk, butter, and eggs is decreasing. People are also using more sunscreen and trying to stay out of the sun. All of this contributes to vitamin D deficiency, which is a growing problem and an important factor in the increasing rates of osteoporosis. See Tables 1, 2, and 3.

    Table 1 – Risk Factors for Vitamin D Deficiency

  • Persons concerned about skin wrinkles and skin cancer who avoid sun exposure
  • Living in temperate to higher latitudes
  • Persons with dark skin
  • Indoor occupations and living
  • Pregnancy
  • The elderly (two-thirds less 7-DHC is produced in the skin)
  • Sunscreen use
  • Fall and winter

    Table 2 – Causes and Effects of Inadequate Vitamin D

    Inadequate Vitamin D Serum Calcium is reduced
    Reduced serum calcium Parathyroid hormone (PTH) is increased.
    Increased PTH Calcium is resorbed from the bones
    Bone calcium resorption Serum calcium is elevated; bone density decreased

    Table 3 – Vitamin D and Calcium

  • Vitamin D stimulates calcium absorption from the gut
  • Vitamin D stimulates calcium reabsorption from the kidney
  • Vitamin D stimulates calcium resorption from bone (when dietary calcium is deficient)

    Many scientists do not consider vitamin D to be a true vitamin, since man can synthesize it internally. See Table 4, How We Make Vitamin D.

    Table 4 – How We Make Vitamin D

    Sebaceous oil glands in the skin secrete 7-dehydrocholesterol (7-DHC) to the skin surface

  • Ultraviolet light converts 7-DHC to cholecalciferol (D3)
  • In the liver, enzymes convert D3 to 25-hydroxycholecalciferol (25-D3)
  • In the kidneys, 25-D3 is converted to 1,25-dihydroxycholecalciferol (1,25-D3)
    1,25-D3 is the active form of vitamin D

    Most of the companies that sell supplements to chiropractors are concerned about hypervitaminosis D and use low levels of vitamin D, even in their bone-building formulas. In my personal experience, I have seen scores of patients with vitamin D deficiency. See Table 5.

    Table 5 – Vitamin D Deficiency Statistics,

  • 25-D3 is the most accurate lab measurement.
  • 50% of non-Caucasian women had deficiency in a South Wales study
  • 75% of adolescent girls needed 800 IU/day in the winter just to maintain normal levels in a Finnish study
  • 50% or more of nursing home patients are deficient
  • 35% of adults over age 50 that were admitted to Massachusetts General Hospital for any reason were vitamin D deficient

    · The farther north you live from the equator the less vitamin D you make. If you live in cities such as Boston, Milwaukee, or Boise you will not make vitamin D from November to February, even if you are in the sun all day. Go further north to Edmonton and you will not make vitamin D from mid October to mid April.

    Conversely, I have never had a case of hypervitaminosis D in my practice. I have found one brand of multivitamin that contains 2000 IU of vitamin D per 3 tablet serving. I have used this successfully with the above-mentioned low vitamin D bone-building formulas in many patients who want to increase bone density. See Table 6.

    Table 6 – Hypervitaminosis Overkill?

  • Extra vitamin D from sun exposure is destroyed by the body
  • At least 2000 IU/day for 18 months is required for toxicity
  • 2000 IU/day is the current no-adverse-effects level (NOAEL)
  • A recent paper states that NOAEL should be 10,000 IU/day

    The reason why vitamin D deficiency is so often overlooked is that there are often no symptoms of deficiency until levels are severely depressed. See Table 7, Vitamin D Deficiency Signs and Symptoms.

    Table 7 – Vitamin D Deficiency Signs and Symptoms 2,3

  • Ricketts in children and infants (knock knees, enlarged joints, pigeon chest, bulging forehead, pot belly, and bowed limbs)
  • Osteomalacia in adults
  • Easy fractures.
  • Muscle twitching and convulsions (tetany)
  • Low serum calcium
  • Gnawing bone pain
  • Increased risk to breast, prostate, and colon cancer
  • Increased risk of falling

    Conversely, by taking a dietary history and analyzing supplements, vitamin D toxicity is much easier to catch. See Table 8, Vitamin D Toxicity.

    Table 8 – Vitamin D Toxicity Signs and Symptoms8

  • High serum calcium
  • Excessive thirst
  • Appetite loss
  • Weight loss
  • Nausea and vomiting
  • Alternating diarrhea and constipation


    1. Code of Federal Regulations, Title 21, Volume 3, Part 184, 2003.

    2. Plehwe, W.E. Vitamin D Deficiency in the 21st Century: An Unnecessary Pandemic? Clinical Endocrinology. 2003; 59: 22-24.

    3. Liebman, Bonnie. Vitamin D Deficiency: The Silent Epidemic. Nutrition Action. 1997; 24(8): 1-6.

    4. Boik, John. Natural Compounds in Cancer Therapy. Oregon Medical Press. 2001

    5. Vieth, R. Vitamin D Supplementation, 25-hydroxyvitamin D Concentrations and Safety. Am J Clin Nutr. 1999; 69(5): 842-56.

    6. Malabanan, A.O., Holick, M.F. Vitamin D and Bone Health in Postmenopausal Women. J Women’s Health. 2003; 12(2): 151-6.

    7. Studzinski, G.T., Moore, D.C. Sunlight – Can it Prevent As Well As Cause Cancer? Cancer Research. September 15, 1995; 55: 4014-22.

    8. Ensminger, A.H., Ensminger, M.E., Konlande, J.E., Robson, J.R. Encyclopedia of Foods and Nutrition. CRC Press: Boca Raton, FL. 1995.


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