Water01 - Thank you for that great post AND for this opportunity to set the record straight about one of Nature's/God's GREATEST healing plants!
That 'warning letter' was sent to virtually every company that was selling herbs at that time (of which the FDA was aware). What is most frustratingly (to me) is that one of the LARGEST companies with the most money to fight the lies (Dr. Christopher's company, now run by his children), willingly chose to kowtow and remove the Comfrey from all their father's products, rather than fight the FDA. So, with one of the major players 'knocked out of the fight', the smaller players (armed with truth & integrity, but very little money), had to shoulder the burden of the battle. And battle they did, and they WON (even if the court costs for them were astronomical with no way to recoup them). Herbalists ARE still allowed to include comfrey in products for internal use legally.
The unneccesary "warning" (regarding comfrey only being safe for external use) is still widely in place...which is VERY frustrating. It is very rare to find someone familiar enough with herbs & natural health/healing that they are not 'scared away' by a "liver damage" & "cancer" warning...so likely millions of people that could benefit from the healing miracles of comfrey are deprived. :( And this is all very similar to the authorities manipulation of the public concept of the safety of natural Ephedra (not the varieties of sythetic kinds or the products that were mixed with other unsafe plants or chemical stimulants). The "scare" about Ephedra even 'got me' for a time. (Note - it's a true shame we don't have a legitimate organization that will test and oversee the marketing of herbal products. There were truly innocent people hurt very seriously by the use of Ephedra products that were adulterated with chemical toxins. And there have been cases of people having all kinds of abnormal reactions and problems from taking herbs that were grown with the usage of DDT and other incredibly toxic chemicals. Besides being a carcinogen, DDT is also a neurotoxin, so there have been people with neurological illnesses that have worsened after taking the very herbs that should help them heal. :(
When I was researching the FDA/Comfrey/Christopher situation, I found (what appears to be) the "final word on Comfrey" from the FDA's website. It is pasted below in it's entirely (as written), and then there's "my review" of the data AFTER running it through my "Spin Detector" (this document puts a theme park ride to shame with the velocity of spin it contains!).
Let's see how good YOUR "Spin Detector" is! Read the document below and discern what you determine & conclude after reading it. After you've finished, ask yourself: Does it provide factual evidence? Is it legitimate? After reading it, does the use of Comfrey concern you? What do you now know about Comfrey that you didn't know before?
Here it is, straight from the mouth of the FDA:
The use of comfrey in dietary supplements is a serious concern to FDA. These plants contain pyrrolizidine alkaloids, substances which are firmly established to be hepatotoxins in animals. Reports in the scientific literature clearly associate oral exposure of comfrey and pyrrolizidine alkaloids with the occurrence of veno-occlusive disease (VOD) in animals. Moreover, outbreaks of hepatic VOD have been reported in other countries over the years and the toxicity of these substances in humans is generally accepted. The use of products containing comfrey has also been implicated in serious adverse incidents over the years in the United States and elsewhere. However, while information is generally lacking to establish a cause-effect relationship between comfrey ingestion and observed adverse effects humans, the adverse effects that have been seen are entirely consistent with the known effects of comfrey ingestion that have been described in the scientific literature. The pyrrolizidine alkaloids that are present in comfrey, in addition to being potent hepatotoxins, have also been shown to be toxic to other tissues as well. There is also evidence that implicates these substances as carcinogens. Taken together, the clear evidence of an association between oral exposure to pyrrolizidine alkaloids and serious adverse health effects and the lack of any valid scientific data that would enable the agency to determine whether there is an exposure, if any, that would present no harm to consumers, indicates that this substance should not be used as an ingredient in dietary supplements.
So now, how ya feelin' about the internal use of Comfrey? Do you feel like you're heard and absorbed the truth? Before you read the "Sarcastic Spin Detector" version below, there's two things you need to know (or remember).
#1 There are pyrrolizzidine alkaloids present in MANY plants, and many are known to cause liver damage, but so far, there is absolutely zero factual evidence that the specific pyrrolizzidine alkaloids in Comfrey have ever caused liver damage or cancer. Here are a few of the plants with PAs that have caused damage: http://lib.bioinfo.pl/pmid:7311596
The inset text below is from this FANTASTIC article of the safey & use of Comfrey: http://www.herbsarespecial.com.au/free-herb-information/comfrey.html
Outbreaks of PA poisoning in humans, in the past, have usually been the result of accidental contamination of food crops, with the toxic seeds of other plants. One such instance was an outbreak of veno-occlusive disease in Afghanistan in 1974. This outbreak followed a severe drought and the people were suffering from acute malnutrition (an important factor). About 22% of the people showed evidence of liver disease when examined in 1975. The cause of the outbreak was traced to bread, contaminated by heliotropium seed (which grew extensively in the wheat fields). Samples of the wheat examined, were found to contain an average of 40 seeds (300 mg) per kg of wheat.
Cases of liver damage, due to people drinking bush teas of seneca and crotalaria, have been reported from a number of places. J. A. Pembery, B.Sc., advisor to the Henry Doubleday Research Association, Essex, U.K. says, in the book ‘The Safety of Comfrey’, that there appear to be no cases, in medical history or veterinary records, of humans or animals, showing clinical symptoms, of pyrrolizidine alkaloid poisoning, from the consumption of comfrey. Lawrence D. Hills, in his forward in the book, mentions that the Commonwealth Bureau of Animal Health very kindly carried out a computer search through their records of 137,000 cases of stock poisoning by plants, since 1972, and found only one concerning case: a case of comfrey-nitrate poisoning in pigs from excessive use of fertilisers in Germany.
#2 At some time in school (likely a long time ago in a science class far, far, away), you probably heard the very valid statement that "correlation does not prove causation" (or "association does not prove causation"). This means, that's just because two things happen to be correlated or associated, it doesn't prove that one causes the other. For example, it may be true that almost always when you're trying to take a relaxing soak in the tub, the phone starts ringing or the kids go ballistic. (That's a correlation or an association). But running a bath full of hot water and getting in it does not CAUSE a phone to ring (or children to misbehave). Hence, correlation/association does not prove causation (although it's possible that when things are correlated or associated, one of them does cause another). But two events happening together does not PROVE one causes the other. One has to do more testing and studying to find out how the events are related.
So, here it is - The Comfrey Bomb (FDA in black - me in cool blue :)
Now then, it is any wonder, that after almost a century of this level of "spin & lies" being imbedded into the minds of society and physicians (AND alternative & natural healers), that we're all scared to death to eat plants to heal ourself? (Of course, this doesn't mean that we should be stupid and run out there and stuff our face with anything and everything just because it's "natural" and someone said it was good for us). But it is VERY important to know the the pharmaceutical industry-owned AMA (whose foundational mission is "to protect the legal & financial interest of it's members") and all it's greedy tentacles, have spent BILLIONS of dollars since the late 1890's,,,,hiring the TOP psychologists and advertising PR experts to propagandize & brainwash society and destroy the competition. And you just saw one little blurb that's part of the process. All of us (and all of those we ever try to help) are victims of this 'fear & quackery' campaign...and how deceitful, impactful, and health-destroying their incredible levels of "spin" really are.
Let truth and freedom REIGN!
"Those who know the least obey the best."--George Farquhar
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