Aaron Morris said:

> Truth be told I've been a bit disappointed with the amount of
> publicity given to the Anti-O properties of honey.  It seems that's a
> message that the NHB (and beekeepers too) should be shouting
> from every mountain top!

Yes, you can shout, but be careful what you shout.

Take extreme care when speaking about antioxidant properties.
Avoid appearing to be making "health claims".  Both the FTC
(Federal Trade Commission) and the FDA (Food and Drug
Administration) have regulatory authority over such claims.

The FTC has stomped hard on several vitamin supplement companies
who made claims about antioxidants, so tread with care.  The states
tend to follow the lead of the FDA and FTC in picking targets for
"enforcement".  Every state has some form of "food and label" group,
who would be the likely enforcing authority to stomp on a beekeeper or
non-national honey packager.

In short, you can shout about antioxidants all you want, but don't make
any claims that antioxidants have any specific impact on health or disease.

In my personal view, the mere statement that honey is "a good antioxidant"
carries the clear implication that there is some health advantage, but the
FDA seems to tolerate this.

But stop there.  Say no more.  Say nothing about what antioxidants
might do for anyone, since that is where you will get into trouble.

Current FDA regulations specify that no diet-disease relationship can be
discussed in labeling unless FDA has determined that the relationship is
supported by "significant scientific agreement." To date, only eleven
categories of health claims have been approved for labeling under this
standard, and none of them have anything to do with antioxidants.

Don't get angry at me about any of this - I'm not denying that the bulk
of the antioxidant studies show advantages to health, I'm just telling
you that the FDA and FTC are not yet convinced.  (I'm a good boy, and
take my betacarotene pills every day.  We also use lots of honey.
Our apiary's motto is "We eat all we can, and sell the rest".)

By "labeling" the FDA means claims that one can make on a product's
label and package, but the term "labeling" has often been read to include
point-of-sale displays, signs, and hand-out flyers when it has come time
to fine offenders and write injunctions.

The FDA likes to see "qualification statements" made when one brings
up things like the "antioxidant properties" of a food or drug.  Here is the
gist of what the FDA would like to see:

  The first level of qualification for an antioxidant claim would be the
  advisory that science will not be sure about the health benefits of
  antioxidants until longer term research is completed.

  The second level qualification would be that some recent studies
  had failed to find a cancer reduction benefit for antioxidant supplements.

  The third and strongest qualification is that a recent study reported that high
  doses of an antioxidant may actually have increased the risk of cancer among
  smokers. This was a reference to a 1994 clinical study of the health effects of
  beta carotene supplementation among smokers in Finland.

But, even a well-qualified statement can be rejected by the FDA.  The FDA is
being sued by Wellness Lifestyles Inc., Pure Encapsulations Inc. and the
American Preventive Medical Association, over the FDA's rejection of
the statement:

   "Antioxidant vitamins may reduce the risk of certain kinds of cancers."

...with an accurate and appropriate disclaimer.

Bottom line, take care.  I've never had to convince anyone that honey
was good FOR them.  It seems enough that honey is "good".  Some
even consider it an decadent indulgence.  I'm not about to argue with them.

        jim

        farmageddon  (where our explosives permits come
                                  in handy at midnight on New Years)