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go a step further and designate it as one of the  women.  Yet the CDC acknowledges that: “[s]erum retinol values do not
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         “nutrients of concern” which would indicate a  always reflect total body status because of homeostatic control and there-
         substantial public health risk.           fore are often not useful for assessing the vitamin A status of individuals.
                                  13
            The FDA provides guidance to manufactur-  Additional tests may be required to confirm vitamin A deficiency when
         ers regarding vitamin supplement labeling: the  20 µg/dL is used as a cutoff.”
         FDA’s “daily value” of vitamin A for pregnant     According to a WHO report, in the U.S. vitamin A status can be
         and lactating women continues to be 8,000 IU,  poor, especially among low-income populations. In children qualifying
         since publication in the Federal Register in  for the Special Supplemental Nutrition Program for Women, Infants, and
         1993.  Recently, the FDA removed vitamin A  Children (WIC), 32 percent were in the “uncertain area” for the modi-
             14
         from its mandatory Nutrition Facts Label for  fied relative dose response (MRDR) values (an indication of low vitamin
         packaged foods, a move they made because  A stores). Furthermore, an assessment of low-income pregnant women
         they claim “[i]n the early 1990s, American diets  showed that an alarming 9 percent were above the international MRDR
         lacked Vitamins A and C, but now Vitamin A  cut-off of 0.060 for vitamin A adequacy (frankly vitamin A deficient).
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         and C deficiencies in the general population  The MRDR cut-off is a more accurate method of determining vitamin
         are rare.”  It is unclear how the U.S. diet has  A status, as explained below.
                 15
         changed to contain more vitamin A. However,     While stating that “high-dose” vitamin A should be avoided in
         because “vitamin A” on a label does not usu-  pregnancy, particularly between day fifteen and day sixty following
         ally indicate the presence of true vitamin A, but  conception, the WHO recommends vitamin A supplementation in re-
         rather carotenoids, this omission may not matter.  gions where deficiency is common for the prevention of night blindness.
            According to the CDC, more than 95 per-  Supplementation of 10,000 IU/day or 25,000 IU/week is recommended
         cent of the U.S. population has adequate serum  for pregnant women in these areas, beginning after day sixty of gesta-
         vitamin A levels of 20 µg/dL or greater, in line  tion and continuing for at least twelve weeks or until delivery.  (Note
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         with the World Health Organization (WHO)  that “high dose” vitamin A of 50,000 to 400,000 IU has typically been
         standard of less than 20 µg/dL used to define  administered within six to eight weeks postpartum in areas of endemic
         public health problems. The CDC has estimated  vitamin A deficiency, with the higher amount being more effective at
         the prevalence of low serum vitamin A among  raising breast milk concentrations. ) Perhaps it would be wise to consider
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         females to be 0.2 percent, or 317,000 American  the real probability that many “well-nourished” American women are


                                                 THE ROTHMAN STUDY

             The study usually cited in support of warnings against vitamin A during pregnancy was carried out by KJ Rothman and
          his team in 1995 at the Boston University School of Medicine and published in The New England Journal of Medicine.
                                                                                                             1
          In the study, researchers asked over twenty-two thousand women to respond to questionnaires about their eating habits
          and supplement intake before and during pregnancy. Researchers found that cranial-neural crest defects increased with
          increased dosages of vitamin A; but neural tube defects decreased with increased vitamin A consumption, and no trend
          was apparent with musculoskeletal, urogenital or other defects.
             This study is a poor rack on which to hang the myriad warnings that have kept pregnant women from eating liver
          and taking cod liver oil. Researchers made no distinction between synthetic vitamin A derived from multivitamins and
          processed foods like margarine, and natural vitamin A from food; nor did they take blood samples to determine vitamin
          A status. Food recall surveys are a notoriously inaccurate method of determining nutrient intake.
             Subsequent studies found that high levels of vitamin A did not increase the risk of birth defects. A 1998 study from
          Switzerland looked at vitamin A in pregnant women and found that a dose of 30,000 IU per day resulted in blood levels
          that had no association with birth defects. 2
             A 1999 study carried out in Rome, Italy found no congenital malformations among one hundred twenty infants
          whose mothers consumed an average of 50,000 IU of vitamin A per day.  Some participants consumed up to 300,000
                                                                       3
          IU vitamin A daily during pregnancy with no birth defects in the offspring. An average of 50,000 IU vitamin A per day is
          consistent with WAPF recommendations of cod liver oil to supply 20,000 IU per day plus additional vitamin A in liver,
          butter, seafood and egg yolks.

          REFERENCES
          1.    Rothman KJ and others. Teratogenicity of high vitamin A intake. N Engl J Med. 1995 Nov 23;333(21):1369-73.
          2.   Wiegand UW and others. Safety of vitamin A: recent results. Int J Vitam Nutr Res. 1998;68(6):411-6.
          3.    Holmes LB. Need for inclusion and exclusion criteria for the structural abnormalities recorded in children born from exposed pregnancies. Teratology. 1999
             Jan;59(1):1-2.
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