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Re: OSR explained

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Thanks Heidi.

I saw it in another group, good info about the product.

Sasmita

>

> I am not advocating OSR is good or bad, since I have not used it nor looked

into it much. But, here is a post I found today that talks about the specific

ingredients.

>

> Love and prayers,

>

> Heidi N

>

>

> Fwd:

>

> >From Boyd re OSR#1 to Chicago Tribune

>

> Below is my response to the Chicago Trib article. We have also had our

> legal help contact the FDA and explain our position. They have extended

> our time to respond in detail until the end of July and implied that

> they are willing to work with us on this issue.

>

> The article by the Chicago Tribune and the warning letter from the FDA

> are fueled by a misconception. The chemical name of OSR#1 is

> N1N3-bis-(2-mercaptoethyl)isophthalamide which makes it sound to many

> like an exceptionally complex chemical with no natural components.

> However, looking at the structure of OSR it is easily seen that it

> contains a benzoate group (found in cranberries) and two cystamines (a

> metabolite of cysteine and found in all mammalian cells and on the

> terminal end of Coenzyme-A). The coupling of cystamine to benzoate is

> through the same type of amide linkage found in connecting amino acids

> to produce protein.

>

> The FDA description of a dietary supplement as extracted from their

> letter is: To be a dietary supplement, a product must, among other

> things, " bear [ ] or contain [ ] one or more...dietary ingredients " as

> defined in section 20 I (11)( I) of the Act, 21 U.S.c.§ 321 (ff)( I).

> Section 20 1(11)( 1) or the Act defines " dietary ingredient " as a

> vitamin, mineral, amino acid, herb or other botanical, or dietary

> substance for use by man to supplement the diet by increasing the total

> dietary intake. or a concentrate, metabolite, constituent, extract or

> combination of any dietary ingredient from the preceding categories.

> Using this description it is obvious to a biochemist that OSR#1 bears

> and contains two dietary ingredients. It appears as if the chemical

> name (which we had to place on the label) has confused this issue.

> Hopefully this can be cleared up.

>

> Regarding the toxic effects the FDA and Chicago Tribune comment on. The

> diarrhea and pancreas problems reported occurred during an UP/DOWN study

> to determine the LD-50 of OSR, that is " what amount of OSR would cause

> 50% of the test animals to die? " . Problem was that during the

> experimentation, even to reach the 5 grams/kg body weight they finally

> achieved, the researchers had to give the OSR (dissolved in corn oil) at

> three different times during the day. Even then the test animals showed

> no weight loss or ataxia or other signs of toxicity except diarrhea and

> a pancreas abnormality. They were giving these animals massive doses

> (e.g. 1,000 to 5,000 times the recommended level for humans) trying to

> kill them. Almost all supplemental materials would cause some problems

> at these levels and the LD-50 of OSR (decided to be greater than 5 g/kg)

> is considerably above the LD-50 of some commonly used supplemental

> compounds used today.

> For example, a 220 lb (100 kg) person would have to take 500 grams/day

> or 5,000 OSR capsules/day to reach the 5 g/kg body weight level. We

> recommend 1 capsule or 0.1 gram/day level usage (i.e. 100mg) which is

> 5,000 times below the 5 gram/kg level in this example. When the long

> term study was done and the maximum amount tested was 1 gram/kg body

> weight the diarrhea and pancreas issues disappeared. At 1 gram/kg a 220

> lb person would have to take 1,000 capsules/day to reach a level where

> no toxic effects were noted. In it's initial letter responding to our

> Premarket Notification the FDA did not mention these test animal

> toxicity studies as being of any concern. I don't know what changed

> their minds to make them go back and review this, but their review and

> the comments in this recent letter do not reflect a concern I would

> agree with.

>

> Also, OSR has never been promoted by CTI Science as a treatment for any

> specific disease and FDA disclaimers are on every package.

>

> I would point out that the FDA warning letter was not based on any

> reported adverse effect. Since CTI Science has been selling OSR (about

> 2 years) we have not had one severe adverse effect reported to our FDA

> based adverse effect reporting system. We have had many very positive

> responses from physicians and parents regarding the use of OSR.

> However, the fact is that I have to obey the FDA directive or risk

> damage to my co-workers as well as myself, and/or spend the funds to

> legally counter the FDA decision. What to do is under study. But from

> the above, you can see why I strongly believe that OSR is a dietary

> supplement by FDA criteria and that it is without detectable toxicity at

> the levels recommended.

>

> Boyd E. Haley, PhD

> Professor Emeritus

>

> University of Kentucky

> Chemistry Department

>

> Boyd E. Haley, PhD

> President

>

> CTI Science, Inc.

>

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