Good day.  This letter is written in response to the NHPD BEEP messages from September 14^th and October 5^th of this year.

I believe that the NHPD’s position on the use and effectiveness of Enzymes may be a bit too conservative.  As a practitioner for over 35 years, I have a yearly recurrence of 5000+ patient contacts.  While I am supportive of the decision to consult with a practicing Naturopath and respect Dr. George Tardik’s point of view, his opinion does not correspond to my clinical experience.

I fear that we may lose Digestive Enzymes as a readily available supplement in the present landscape of natural health products in Canada.  I have served as an expert advisor for committees overseeing herbal and botanical preparations in Canada since the 1980’s; stand as the acting President of the Canadian Council of Herbal Associations (an advisory council for provincial herbal associations); and have been an active member of the NHP-PAC for over a year now.  A variety of enzyme-based preparations have been in clinical use for over 150 years in North America, and even longer in some Canadian cases. As of today, a large number of enzyme-based natural health products have had DINs for more than 30 years.  As far as I know, there have been no reported cases of toxicity or adverse effects on health.

Background

Digestive Health is the cornerstone of many traditional medical practices around the world (references available upon request). To illustrate a few key points:

1. In Ayurvedic medicine (with a history of over 2000 years), problems with the accumulation of undigested foods (referred to as ama) are the starting point or ‘water shed’ issue of many adverse health conditions. Ama is considered a toxin or poison that causes deep health imbalances ranging from digestive (e.g. colon) complications and headaches, to joint inflammation, arthritis and even certain forms of cancer.
2. In Traditional Chinese Medicine, the issue of poorly digested food is referred to as Stagnated Food Qi (‘chi).  It, too, is considered to be the root of a variety of poor health conditions.  Beyond the simple problems of belching and epigastric pain, Stagnated Food Qi is also considered a poison in the body that ‘insults’ (i.e. disturbs) the Liver and Spleen/Pancreas.  This can lead to a cascade of adverse health conditions such as deficiencies, followed by inflammation, and eventually an advanced or degenerative disease.
3.  In North America, both Physiomedical and Eclectic traditions from the mid-19^th to early 20^th centuries considered digestion as the cornerstone of health in the human body.  To established figures such as Samuel Thomson, William Cook, Dr. Felter, and Professor King (who formulated the basis of the first United States Pharmacopeia), this was the root of most health complications.  Many prominent Herbalists have kept these practices and traditions alive into present times.  Plainly stated, without the adequate digestion of food, toxins can accumulate in the body and many adverse health issues will follow.

The multi-cultural background of natural healing reflects the current opinion of many practitioners in Canada.  The biggest issue I have heard from a variety of practitioners in Canada is the statement that: “ . . . on a review of the totality of evidence, NHPD has determined that products containing any of the above-mentioned enzymes will require a maximum duration of use of 3 days unless specified otherwise.”

As a first remark, there appears to have been a misinterpretation of the information provided by your consultant, Dr. George Tardik, N.D.:

“To any reasonable level of accuracy, the safety of most enzymes in oral form for digestive purposes is unknown in long term use.  Research conducted for the purposes of digestion varies from 24-72 hours (refer to enzyme templates) with some research on non-digestive purposes extending up to 7.5 weeks (Braun et al. 2005).  Theoretically in healthy adults, chronic use of digestive enzymes may down regulate endogenous enzyme production.”

1. The fact that no official study has been conducted on the long-term use of enzymes (for digestive and/or non-digestive purposes) in no way means that there are adverse health effects associated with their long-term use.  This simply indicates that there has yet to be enough of an incentive to investigate and finance a study of this nature.
2. “Theoretically in healthy adults… …may down regulate endogenous enzymes…”  This is a doubly vague statement that is certainly not provide enough evidence from which to base a 3-day maximum policy for the consumption of enzymes.

The vast majority of people who purchase and consume Digestive Enzymes in Canada have impaired digestion.  This means that we cannot consider them to be healthy adults in the arena of digestive health.  Although I intellectually understand Dr. Tardik’s position on the matter, I find this to be a regression to the common perceptions of the 1970’s and 1980’s.  In my clinical practice during this era, I seldom suggested the use of Digestive Enzymes, as there simply wasn’t a need for them.  Our ever changing diet(s) in Canada has moved further away from a ‘traditional diet’ and more toward a ‘convenient diet’ (e.g. fast foods).  Add to this our increasing levels of daily stress, occupational and otherwise, and I fear that digestive health has suffered tremendously.

I now find that an overwhelming proportion of my clinical practice is focused on helping people improve their digestion.  The protocols suggested often require the use Digestive Enzymes for months at a time until the body is capable of fully taking over digestive function without supplemental assistance.  Herbal and botanical preparations are also included in these protocols.  While our mutual goal with Dr. Tardik may be to avoid creating a dependency on Digestive Enzymes, our timeframes for achieving these goals are substantially different.

Setting a 3-day limit on the use of enzymes is very misleading to the public in general. Though certain people only use digestive enzymes prior to consuming a large/’rich’ meal (typical of the festive season), the majority use them on a semi-long-term basis.  This is particularly true for people over the age of 60, whose digestive health has steadily deteriorated over the years.

I fear that with a 3-day limit on the use of Digestive Enzyme, we will exacerbate and increase the occurrence of digestive health problems.  Since such a large portion of the Canadian population employs the present use of Digestive Enzymes, neglecting to substantiate this 3-day claim with clinical evidence may cast doubt in the public eye as to the integrity of the NHPD.

Terry Willard ClH, PhD