The deadly dozen dubiously-salubrious denizens of the DA (Drug Administration)

Jim Duke

When the FDA outlawed supplements of tryptophan (essential to life), which probably occurs in all living and recently dead animals and plants, I interpreted that as suggesting that tryptophan must be a pretty promising nutritional supplement. Though environmental, health, and safety debates always have two sides, I am convinced that tryptophan was not the culprit, rather a technologically introduced contaminant, which killed more than 30 people. Tryptophan, though still on the FDA hit list and still illegal as a supplement, occurs in every plant and animal you consume. (Seed of evening primrose, busted at least 4 times by the FDA, is the best source of tryptophan in my database.) There's one strange conflicting connection; some US scientists, who will make more money if tryptophan and melatonin are moved from OTC to prescription-only availability, may have influenced the FDA campaigns against melatonin and/or evening primrose. One super scientist with financial ties to these chemicals or pharmaceuticals that share the same activities, has shown that dietary tryptophan contributes to cerebral serotonin, in that sense satisfying some of the same circuitry satisfied by Prozac. So Prozac is still legal, selling more than a billion dollars a year, while supplementary tryptophan is illegal, and evening primrose, the best natural source of tryptophan has been busted. I have told herbal friends not to despair, that FDA disapproval of an herb or supplement often stimulates sales, so popular and credible is the belief that the FDA is in the pockets of the pharmaceutical propagandists. I suspect that many real scientists in the FDA, if they weighed the evidence, would rather their daughters took angelica than calcium blockers, celeryseed than allopurinol, evening primrose than Prozac, feverfew than sumatriptan, ma huang than amphetamine, rosemary than cognex, St. John's-wort than Prozac, soybean or other tastier estrogenic legumes than tamoxiphen.

Yes, the FDA has banned tryptophan, biotechnologically contaminated versions of which killed more than 30 people and caused perhaps hundreds of cases of EMS. But OTC and prescription pharmaceuticals, approved by the FDA, take thousands of lives each year. Now for an honest confession from an herbalist! Herbally-derived drugs of abuse probably kill more than a million Americans each year. And starting in 1995/6, Dr. Kessler, FDA Commissioner, finally took on the real herbal enemy, an Amerindian herb known as tobacco, Nicotiana. Though Amerindians historically used the herb ceremonially without becoming addicted, more than a quarter of Americas have smoked, and most of them became physiologically addicted, including yours truly. For more than two decades I smoked three packs a day, king-sized, unfiltered. Now I've switched from cancer sticks to carrot sticks, hoping that the mix of carotenoids, unlike isolated beta-carotene, will prevent the lung cancer I invited with all that smoke pouring through my lungs. This is the worst of the killer herbs, killing perhaps half a million Americans and more and more unAmericans every year. The next worse killer herbs are those used to make the often-abused alcohol. (Any sugar producing herb can be used to manufacture alcohol; among the most frequent, sugarcane, corn, potato, grapes, barley, hops, etc.) Though the poison ethanol kills many Americans, we don't ban the corn, our number two crop, nor the grapes, or potatoes. I frankly don't know which is the next worse killer, cocaine (From Erythroxylum spp.), heroin (from opium from Papaver somniferum, one of our Biblical herbs), or marihuana (Cannabis sativa) or its derivatives, hashish, or medicinal THC or marinol. I was once accurately quoted as saying I'd rather my kids smoked an occasional joint than chronically smoked tobacco. But I think that habitual smoking of equal amounts of marijuana as a substitute for smoking tobacco would be as bad as or worse than smoking tobacco. Coca, marijuana and opium poppy are banned for planting in the US. But all of these killers have legitimate uses. The FDA approves some medicinal uses of alcohol, codeine, cocaine, marinol, and morphine, e.g., and poppy's paverine is injected into more than one penis in the US, additional to its use in other areas. A few deaths attributed to jimsonweed and its generic relatives (Datura spp.) and ma huang (Ephedra), but solely or almost exclusively when used recreationally.

If more people are going to "quacks" (alternative practitioners), even when they have to pay out of pocket, than are going to allopathic physicians, more often covered by HMOs or insurance, as seems to be the case starting this decade, why is it that there are several orders of magnitude more fatalities associated with allopaths than with quacks?

Table of Fatalities

(Rounded no. of fatalities/no. people involved with procedure or medicine or herb)

Other estimates (food poisoning, murder, based on total population of 250 million.

Herbs 1/1,000,000 (JAD)

Supplements 1/1,000,000 (JAD based on tryptophan)

Mushroom Poisonings 1/100,000 (JAD)

Food Poisoning 1/25,000 (CSPI)

NSAIDS 1/10,000 (CMR)

Murders 1/10,000 (WTOP)

Surgery in Hospital 1/10,000 (JAMA)

Car Crashes 1/5,000 (JAD)

Improper Taking of Medication 1/2,000 (JAD)

Angiograms 1/1,000 (JAD)

Medicine (even in hospital) 1/1,000 (JAMA)

Alcohol 1/500 (JAD)

Cigarettes 1/500 (JAD)

Medical Mishaps 1/250 (AARP)

Iatrogenic hospital infections 1/80 (JAD)

Bypass Operations 1/20 (JAD)

Calculation of fatality ratios by me(=-JAD):

27 died to tryptophan (assume 27,000,000 nutrient poppers=1 in a million).

Ca 2 herbal fatalities a year; assume conservatively only 2 million Americans(<1%; real figure could be closer to 25,000,000 {10% of Americans}) are taking herbs = 1 in a million

Mushroom Poisonings: Assumes twice as many among mushroom users as among herbal grazers, and assuming there are 5 times more of the latter. (JAD)

WTOP announced that there were more than 23,000 murders in 1992, which I rounded up to 25,000 over the population of 250,000,000

Center for Science in the Public Interest announced that 10,000 people died of food poisoning last year, 10,000/250,000,000 =1 in 25,000

Assumes car fatalities will run 50,000 (The rate has gone down of late) 50,000/250,000,000 = 5/25,000 = 1/5,000

Cigarettes 100,000 out of 50,000,000 smokers = 1 in 500

Alcohol* 100,000 out of 50,000,000 drinkers (25,000,000 problem drinkers) = 1 in 500

Angiograms 1,000-5,000/yr of 1,000,000 = 1 in 200 to 1 in 1,000

NSAIDS 10,000-20,000/yr assume 40% take =1 in 10,000 to 1 in 5,000

Bypass Operations 14,000-28,000 1 in 10 to 1 in 20

AARP newsletter 1992 1 in 250 to medical mistakes

JAMA 1987 1 in 1,000 entering hospital will die of medication.

100,000 patients lost to hospital acquired infections. CMR May 13, 1985 Or 100,000 out of 8,000,000 = 1 in 80

Medical mistakes ca 200,000 per year assuming. 200,000,000 hospitalizations/year = 1 in 1,000 (Harvard's L. L. Leape) (Good Housekeeping, Oct. 1992, p. 124)

Improper Taking of Medication 125,000 per yr/ assume 250,000,000 = 1 in 2,000 (Approximately 125,000 Americans die each year from failure to take their medicine properly... Ca 30-50% of the 1.8 billion prescriptions dispensed annually are taken incorrectly by the patient.)

My first medicinal plant book that is still in print, the "CRC Handbook of Medicinal Herbs", was submitted to the publisher under the title of "Herbs of Dubious Salubrity". Why that title? Because the FDA had called me on most of those herbs, looking for bad things about them, a few days or weeks before the Herb Industry, looking for good things about them. In this syllabus, I may have erred on the good side of things, but I think I am being even handed. I do not, as a relatively respectable writer, want to be seen as advocating any dangerous herbs. And there are some dangerous herbs. Some of the most dangerous poisons in the world are natural compounds found in Mother Nature's benevolent plant kingdom.

Here I visualize two categories of poisonous plants, the most poisonous having been used and exploited, one way or another by the pharmaceutical industry and to a lesser degree by the herbalists, and the less poisonous having been used frequently by herbalists and less so by the pharmaceutical industry. There are hundreds that fall into each, admittedly poorly defined, category but for simplicity's sake, I have limited our class discussion to a barker's dozen.

CAVEAT: No herb nor synthetic drug, is dangerous, if properly used. All herbs contain antiallergens and allergens, anticarcinogens and carcinogens, antimutagens and mutagens, antioxidants and prooxidant, antitoxins (antidotes) and toxins and thousands of other pro and con phytochemicals. There are probably safe, medicinal, toxic and lethal doses for all chemicals, natural and synthetic. Your genes may well have memory of natural toxins which challenged your ancestors. Your genes, though quick to learn, have no knowledge or memory of tomorrows synthetic drugs and poisons.


Atropa belladonna L. "Belladonna" (POTATO FAMILY)

Conium maculatum L. "Poison Hemlock" (CELERY FAMILY)

Convallaria majalis L. "Lily of the Valley" (LILY FAMILY)

Datura stramonium L. "Jimson Weed" (POTATO FAMILY)

Euonymus atropurpureus Jacq. "Wahoo" (BITTERSWEET FAMILY)

Hyoscyamus niger L. "Henbane" (POTATO FAMILY)

Mandragora officinarum L. "Mandrake" (POTATO FAMILY)

Phoradendron flavescens (Pursh.) Nutt "Mistletoe" (MISTLETOE FAMILY)

*Physostigma venenosum Balf. "Ordeal Bean" (LEGUME FAMILY)

*Phytolacca americana L "Pokeweed" (POKEWEED FAMILY)

Podophyllum peltatum L. "Mayapple" (BARBERRY FAMILY)

*Ricinus comunis L. "Castorbean" (SPURGE FAMILY)

Sanguinaria canadensis L. "Bloodroot" (POPPY FAMILY)

Solanum dulcamara L. "Bittersweet Nightshade" (POTATO FAMILY)

*Taxus spp. "Yew" (YEW FAMILY)

Vinca spp. "Periwinkle" (DOGBANE FAMILY)

Viscum album L. "European Mistletoe" (MISTLETOE FAMILY)


Acorus calamus L. Calamus (AROID FAMILY)

Aesculus hippocastanum L. Horse Chestnut (HORSE CHESTNUT FAMILY)

Arnica montana L. "Wolfbane" (ASTER FAMILY)

Artemisia absinthium L. "Absinth" (ASTER FAMILY)

Corynanthe yohimbe Schum. "Yohimbe" (COFFEE FAMILY)

Cytisus scoparius (L.) Link. "Scotch Broom" (LEGUME FAMILY)

Dipteryx odorata (Aubl.) Willd. "Tonka Bean" (LEGUME FAMILY)

Eupatorium rugosum Houtt. "Snakeroot" (ASTER FAMILY)

*Glycyrrhiza spp. "Licorice (LEGUME FAMILY)

*Hedeoma pulegioides (L.) Pers. (MINT FAMILY)

Heliotropium europaeum L. "Heliotrope" (BORAGE FAMILY)

Hypericum perforatum L. "St. John's-wort" (ST. JOHN'S-WORT FAMILY)

Ipomoea jalapa Nutt. "Jalap Root" (MORNING GLORY FAMILY)

Ipomoea purpurea (L.) Roth "Purple Morning Glory" (MORNING GLORY FAMILY)

*Larrea tridentata (Sesse & Moq. Ex DC.) J. M. Coult. (CALTROPS FAMILY)

Lobelia inflata L. "Lobelia" (LOBELIA FAMILY)

Matricaria chamomilla L. "Chamomile" (ASTER FAMILY)

*Mentha pulegium L. "European Pennyroyal" (MINT FAMILY)

*Piper methystichum Forst. "Kava-Kava" (BLACK PEPPER FAMILY) The campaign against this innocuous herb which I find to be a pleasant sedative, began in early 1997 with a media frenzy following intoxications at a New Year's Eve party

Sassafras albidum (Nutt.) Nees "Sassafras" (LAUREL FAMILY)

*Senecio aureus L. "Squaw Weed" (ASTER FAMILY)

Symphytum spp. "Comfrey" (BORAGE FAMILY)

*Tanacetum vulgare L. "Tansy" (ASTER FAMILY)

*Teucrium chamaedrys "Germander" (MINT FAMILY)

*Tussilago farfara L. "Colt's Foot" (ASTER FAMILY)

* My additions from the popular press ( not included in FDA Directive 7117.05) FDA Directive 7117.05, Transmittal 77-21 (03/22/77) categorized 27 herbs as "unsafe" and I have assigned those, albeit arbitrarily, to the Really Dangerous and the Media Dangerous based on my personal evaluations of more than 20 years, during which times I have ingested more than half of them... "The Bureau of Foods will consider regulatory action against those herbs which fall within the unsafe category (see attachment) and which become adulterated foods by use in herbal teas or otherwise.. . .Formal statements on Calamus, Safrole and Coumarin (from tonka bean) are found in 21 CFR 121.106 and on Stramonium (Jimsonweed) in 21 CFR 250.12)

(See Appendix 2: Biting the Biocide Bullet)

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