I sent an email to [email protected] with the
accompanying article:

Mr. Bela Berkes
P.O. Box 445
Solano Beach, CA  92075

Dear Mr. Berkes:

It is our understanding that some of your distributors
and customers have recently been asking questions
about the safety of silver in your product based on a
recent advance notice of proposed rule-making by the
Food and Drug Administration.

Recent comments contributed by this institute to the
FDA in response to its proposed rule-making point out
that silver is a dietary supplement under the meaning
of 21 U.S.C. Section 321 (ff), if it is labeled as a
dietary supplement and not labeled for therapeutic
use. Under this section of the Food, Drug and Cosmetic
Act, known as the dietary Supplement Health and
Education Act of 1994, a dietary supplement, including
a mineral, intended to supplement the diet, and
intended for ingestion, and labeled as a dietary
supplement may not be prohibited from being marketed
unless the product "presents a significant or
unreasonable risk of illness or injury" when consumed
in accordance with its recommended or suggested
labeling or under ordinary conditions of use.

In this regard, you should be advised that we recently
completed an extensive review of the scientific
literature on the safety of silver, especially as it
relates to its one known potential side effect,
namely, Argyria. Argyia is an irreversible
discoloration of the pigment (skin) caused by
excessive silver intake or chronic exposure to silver
by certain tissues. The amount of silver required to
develop Argyria is estimated to be 3.8 grams per day. 
By comparison standard 10 ppm colloidal silver
contains silver in amounts equaling less than 1
milligram of silver (1,000 micrograms = 1 milligram;
1,000 milligrams - 1 gram), which therefore represents
an amount approximately 1/500th to 1/1000th of the
amount of silver considered to be a risk in the
development of Argyria.

Most cases of Argyria reported in the medical
literature over the last 100 years involved chronic
intravenous or intramuscular use of the silver
preparations, most often involving a silver drug
prescribed by physicians which in most cases contained
silver nitrate. Other cases of Argyria reported in the
medical literature involve application of silver
preparations used for many months or years in the
treatment of the eye or vagina for certain diseases.
We could not locate a single case of orally consumed
colloidal silver manufactured in the last 25 years
causing Argyria in our review of the literature. This
is probably due to the low levels of silver contained
in such preparations, since only very small amounts of
silver are needed for its antiseptic effect.

Humans consume approximately 100 micrograms of silver
every day in the diet. Additional amounts within this
range would be considered safe by all reasonable
estimates, especially if the amount needed to develop
Argyria would be equivalent of 380,000 micrograms (or
3.8 grams) of silver a day.

As for the efficacy of silver preparations, we found
considerable scientific evidence published over the
last 75 years that a number of silver compounds can be
effective germicidal (antiseptic) agents against
several hundred pathogenic organisms. However, silver
is not termed an antibiotic as some have claimed
because an antibiotic by definition is derived from a
living organism.

I hope this information is of assistance. We
appreciate the concerns expressed at this time by some
of your distributors and customers based on the recent
proposed rule-making of the FDA. However, that
rule-making seems directed at OTC drug-like silver
preparation, products that contain magnitudes of
silver greater than might be found in a normal
colloidal silver product.

Sincerely,

Alexander G. Schauss, Ph.D.
Director, Life Sciences Division
John Hopkins University                               

Dr. Alexander Schauss, Ph.D.

Alexander G. Schauss, Ph.D., is the Director of the
Life Sciences Division of the American Institute for
Biosocial Research, Inc. in Tacoma, WA. He is a member
of the Government's Commission on Dietary Supplements.
He holds joint faculty positions as Associate
Professor of Research and Senior Director of Research
and Development at the Southwest College of
Naturopathic Medicine and Health Sciences, in Tempe,
AZ. And, as Associate Professor of Behavioral Sciences
at the National College of Naturopathic Medicine in
Portland, OR. 

Dr. Schauss is an Emeritus Member of the New York
Academy of Sciences, former Chairman of the Food
Policy Council of the National Council for Public
Health Policy, Founding Member of the British Society
of Nutritional Medicine, Emeritus Executive Director
of the American Preventive Medical Association,
Emeritus Executive Director and current President of
Citizens for Health, and a member of the American
Public Health Association and the American Association
for the Advancement of Science. 


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