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The House Committee on Energy and Commerce
Subcommittee on Oversight and Investigations
July 23, 2003
10:00 AM
2123 Rayburn House Office Building
What is a Dietary Supplement?
There exist three categories of chemical agents available for weight loss
treatment. The first two categories are prescription drugs and over-the-counter
drugs. The Federal Drug Administration (FDA) regulates these agents under
carefully controlled guidelines for safety and efficacy. The process is
particularly rigorous for weight loss agents as over 60% of Americans are now
overweight or obese, excess adiposity effects increasing numbers of vulnerable
children and adolescents, and drug treatments for weight loss have a notorious
past history of both abuse and damaging physical and behavioral effects
extending back over a century. Prescription and over-the-counter drugs are
rigorously tested using modern scientific guidelines and procedures to ensure
public and individual safety.
In 1994 a third category of agents emerged referred to as "dietary
supplements". The term dietary supplements is a legal one as stated by the
FDA: "FDA regulates dietary supplements under a different set of
regulations than those covering "conventional" foods and drug products
(prescription and Over-the-Counter). Under the Dietary Supplement Health and
Education Act of 1994 (DSHEA), the dietary supplement manufacturer is
responsible for ensuring that a dietary supplement is safe before it is
marketed. FDA is responsible for taking action against any unsafe dietary
supplement product after it reaches the market. Generally, manufacturers do not
need to register with FDA nor get FDA approval before producing or selling
dietary supplements. Manufacturers must make sure that product label information
is truthful and not misleading. FDA's post-marketing responsibilities include
monitoring safety, e.g. voluntary dietary supplement adverse event reporting,
and product information, such as labeling, claims, package inserts, and
accompanying literature. The Federal Trade Commission regulates dietary
supplement advertising." Dietary supplements for weight loss, unlike
traditional drugs, often include multiple ingredients; the word
"supplement" is misleading as most agents do not "add" to
the natural body stores of the compound nor does the agent usually prevent or
correct a deficiency state.
What Are Some of the Most Popular Weight Loss Products?
Weight loss can be produced when ingestion or absorption of calories or
energy is less than energy released from the body as heat. Dietary supplements
purportedly produce weight loss by suppressing appetite, reducing absorption,
increasing heat production or metabolic rate, and changing the proportion of
calories stored as fat and muscle.
The ephedra alkaloids, discussed below, are thought to suppress appetite and
increase energy expenditure, by two different mechanisms. These actions are
enhanced with herbal sources of caffeine and aspirin are added to the ephedra-containing
product.
Some agents are reported to reduce fat and thus energy absorption from the
gastrointestinal tract, notably chitosan. Chitin is a substance derived from the
exoskeletons (shells) of arthropods such as crabs, shrimps, and lobster.
Some dietary supplements reportedly increase the storage of ingested nutrient
as muscle and decrease the proportion stored as fat. These include the herbal
ingredient garcinia cambogia and the widely used group of compounds referred to
as chromium picolinate and other chromium salts.
My colleagues and I have reviewed these agents in a recent report (1).
I would now like to focus some specific comments on dietary supplements that
include MaHuang as the main active ingredient. I select MaHuang because
consumers are exposed with these products to a potentially dangerous family of
ingredients, the ephedra alkaloids, that not only produce weight loss but that
may lead to strokes and heart attacks with associated disability and death in
selected susceptible patients.
A key concern is that overweight and obese patients are particularly
vulnerable to taking purported dietary supplement weight loss products because
they are often desperate, want to lose weight quickly, find physician
evaluations time consuming and costly, and have often tried dietary and medical
therapies of limited current effectiveness.
By avoiding medical oversight, overweight and obese consumers purchasing
dietary supplements make the false assumption that dietary supplements and
herbal preparations are inordinately safe and may pose no or very little risk.
Moreover, many overweight and obese consumers harbor "silent" diseases
such as high blood pressure and narrowing of the coronary arteries that manifest
under the biological conditions produced with ingestion of the purported weight
loss agent. The overweight consumer of dietary supplements who harbors a
potentially silent killer may be bypassing the critical medical oversight needed
to detect, prevent, or treat a serious underlying medical condition. A large
percentage of overweight and obese Americans have undiagnosed and untreated
medical conditions (2).
What is MaHuang?
MaHuang, now defined as a dietary supplement in the US, is primarily used
today as an ingredient in herbal weight loss products and acts to lower appetite
and potentially increases energy expenditure through stimulant mechanisms
(3-12).
MaHuang is the Chinese name of Ephedra sinica, an acrid tasting stimulant
herb (1). Other Ephedra species include Ephedra equisentina and Ephedra
intermedia.
What are the Active Ingredients in MaHuang?
The ephedra alkaloids represent a family of compounds that vary in proportion
depending on plant species, harvest season, weather conditions, geographic
location, and other factors. The ephedra content of dietary may vary
substantially from label claims (13).
The ephedra alkaloids include the major component, up to 90%, (-)-ephedrine,
up to 30% pseudoephedrine, and lesser amounts of (+/-)-norephedrine or
phenylpropanolamine, and (+)-norpseudoephedrine or cathine. The +/- refers to
the three dimensional positioning of atoms within the molecule and this feature
of a molecule may influence its biological activity.
Ephedrine, an ephedra extract, was synthesized in 1927 and is also widely
used today in weight loss and other pharmaceutical preparations, particularly in
Europe. Although studies are limited, the pharmacokinetics of synthetic and
botanical forms of ephedrine appear similar (14; Appendix I); some questions on
drug disposition remain and more studies are needed (15). Pharmacokinetic
properties of a drug describe its absorption, distribution, and elimination from
the body.
The chemical structures of ephedrine and other ephedra alkaloids are very
similar to the hormones epinephrine or adrenaline and nor-epinephrine. These are
the "flight and fight" hormones that have many important biological
effects including increasing blood pressure, respiration, heart rate, and
arousal. Ephedra alkaloids are also very similar in structure to the banned
group of chemical compounds referred to as amphetamines (Appendix II). Widely
used five decades ago for weight loss and other stimulant effects, amphetamines
are addicting and have many serious other side effects.
How Does MaHuang Produce Weight Loss?
Ephedrine alkaloids appear to exert their main weight loss effects by
suppressing appetite and thus food intake via central "sympathomimetic"
(beta-agonist) actions. Ephedrine alkaloids also appear to have a small effect
on increasing energy expenditure (16). Taken collectively, the ephedra family of
compounds promotes negative energy balance and weight loss by lowering both
energy intake and increasing energy expenditure. Ephedrine and other Ephedra
alkaloids have variable stimulant effects (1,16).
Ephedrine and ephedra alkaloids alone have modest weight loss effects and
their efficacy appears to be enhanced by addition of caffeine and aspirin either
as the pharmaceutical grade ingredients or as their natural counterparts such as
Guarana and Willow-bark, respectively (17-21).
Addition of caffeine (i.e., "Guarana") and aspirin (i.e.,
Willow-bark) to MaHuang purportedly potentiates the actions of ephedrine.
Caffeine competitively antagonizes adenosine receptors and may be an adrenaline
antagonist; adenosine is a hormone produced by endothelial cells that dilates
blood vessels. Many commercial weight loss preparations include varying
proportions of these three components. Caffeine has a small thermogenic (i.e.,
heat-producing) effect in humans (16,17). Aspirin has actions that also
potentiate ephedrine actions.
Is MaHuang Effective as a Weight Loss Agent?
There are many studies that have examined the effectiveness of ephedrine
alone or in combination with other ingredients; fewer studies examine the weight
loss effects of ephedra alkaloids in combination with other natural sources of
caffeine and aspirin.
The collective studies strongly support the premise that ephedrine,
particularly in combination with caffeine and also aspirin, promote significant
short-term (~3-6 months) weight loss when ingested as part of an intervention
program including dietary and lifestyle management. Long-term (>6 months)
controlled trials with large and diverse subject populations are lacking. The
evidence for ephedra efficacy is summarized in the recent Rand Report (Appendix
III).
The efficacy of MaHuang, separate from that of chemically synthesized
ephedrine, is supported by fewer published abstracts and papers, although
conceptually, there is no reason to expect a "large" difference
between "natural" ephedra and chemically-synthesized ephedrine. As
noted earlier, the pharmacokinetics of chemically synthesized and botanical
sources of ephedrine appear similar (Appendix I).
A major limitation of reviewed research is that most studies administered
ephedrine or MaHuang in forms that mimic commercially available preparations and
thus: the efficacy of ephedrine as a sole weight loss agent is not entirely
clear and is questionable; the efficacy of ephedrine with varying amounts of
caffeine and aspirin is difficult to ascertain as studies failed to include
varying amounts of these other agents independent of ephedrine or as separate
experimental limbs in controlled trials.
Ephedrine is used in association with caffeine and aspirin, or their herbal
equivalents guarana and willow bark, to produce the "fat-burning stack
(18)." The stack has some evidence to support its efficacy and is used in
Europe. The three compounds, when taken in the following ratio, 200 mg
caffeine/60mg epihedrine/300mg aspirin, produces a significant thermogenic
effect. Very limited published information is available on the safety and
efficacy of the "stack" or related products.
A concern is that the concentration of ephedrine in the plant and method of
preparation vary widely among products (13). Product labels may therefore not
reflect actual ingredient content or bioavailability.
Are Ephedra-Containing Products Safe?
Why do we know that ephedra alkaloids may be unsafe in some consumers?
Scientists know that ephedra alkaloids, particular when used in combination with
potentiating agents that include caffeine and aspirin, produce variable
increases in blood pressure, heart rate, cardiac output, and respiration (Table
1). These effects in susceptible individuals can trigger heart attacks and
strokes. These effects are well summarized in JAMA's patient page attached in
Appendix IV.
The molecular basis of the stimulant effect for the class of compounds,
"sympathomimetic agents", is well known. While the effects of ephedra
alkaloids alone or in combination are often small in magnitude and transient,
given the large and potentially medically vulnerable obese population taking
these agents we can predict that some individuals will have a relatively large
drug-induced biological effect. Others may have only a small effect, but remain
medically vulnerable due to silent underlying heart or cerebrovascular diseases.
Many of the patients taking these agents do so in the complete absence of
medical supervision or evaluation. They may inadvertently take a large dose due
to product variation or consciously in the hope of boosting their weight loss.
Unsupervised, they may unduly exercise or take excessive amounts of caffeinated
beverages or aspirin. The predictable result, given the millions of Americans
taking these products, is serious medical events including heart attacks and
strokes.
Given the well-recognized risks of this group of dietary supplements and the
appropriate lack of interest in the area by pharmaceutical companies, there
exist very few careful safety and efficacy trials that meet the current
standards set forth for evaluation of pharmaceutical weight loss agents.
In the studies carried out by my colleagues and I using a commercial weight
loss product containing ephedra and caffeine as active ingredients, some
patients in the "active" treatment group experienced untoward effects
at "usual" doses such as palpitations, blood pressure elevations, and
other typical stimulant effects that led to their discontinuation in the study
(21). I have observed similar effects in other unpublished ephedra studies
carried out at our institution. These effects are the well characterized
sympathomimetic effects that I mentioned earlier and that support our projection
that some medically unscreened patients with underlying disease may suffer heart
attacks and strokes following ingestion of this or similar dietary supplements.
This projection is supported by the study of Haller and Benowitz (23)(Appendix
V) and Bent et al (Appendix VI).
A concern regarding the well controlled clinical trials is that subjects were
appropriately medically screened prior to entry into the trial so as to reduce
the medical risks of those exposed. One such trial was carried out at our
institution (22) and only those subjects deemed medically acceptable were
entered into treatment. Rigorous testing of blood pressure and heart rhythm was
used to detect and eliminate those subjects who may have suffered a serious
adverse event during the trial. The lack of serious injuries and side effects in
trials such as these cannot be interpreted as a safety endorsement as the actual
consumer population still includes the medically vulnerable and unscreened
individual who may harbor a potentially lethal silent disease manifest by
ingestion of ephedra alkaloids.
Specifically, concerns have been raised about the safety of products
containing MaHuang/ephedra. Several serious case-reports of adverse effects and
fatalities have appeared in the literature. Strokes, myocardial infarction, and
cardiac arrhythmias are reported in association with ephedra ingestion. Benowitz
and Haller (23; Appendix VI) provided the FDA with an independent review of
adverse events related to ephedra alkaloid containing supplements. The authors
concluded that ephedra alkaloids may pose a health risk for selected
individuals. Some of the reported side effects in patients occurred within the
commonly used therapeutic ranges.
Ephedrine alone or combination with other ingredients may raise heart rate
and blood pressure (e.g., systolic BP increase ~3-7 mmHg) in some subjects
(1-23), although the magnitude and length of time for which these adverse
effects remain evident is not well established. Restlessness, headache, and
insomnia have been reported by subjects ingesting some commercial dietary
supplements and with synthetic ephedrine-caffeine combinations. Subjects with
bleeding tendencies may be at risk when taking aspirin-like compounds.
MaHuang taken alone or combination with other agents may place certain
subjects at risk of adverse and potentially fatal effects. More long-term safety
data, beyond six months, is needed, particularly in selected populations such as
the elderly.
Finally, there exists particularly vulnerable populations such as pregnant or
lactating women, the elderly, and subjects with eating disorders in whom
particular concern exists for their use of weight loss dietary supplements.
Should the Regulations for Dietary Supplements be Changed?
Although my review here has been brief and focused, we can envision four
groups of dietary supplement for weight loss: safe and ineffective; effective
but unsafe; ineffective and unsafe; effective and safe. At present most of the
available dietary supplements fall into one of the first two categories.
Safe and ineffective: This group of products provides false hope to the
unwitting highly vulnerable overweight or obese consumer and may delay their
entry into an appropriate medical or nutritional care system.
Effective but unsafe: This group of products is more dangerous and actual
product efficacy will lure consumers into trying the product while erroneously
assuming dietary supplements, because of their herbal or natural ingredients are
unduly safe compared to their pharmaceutical counterparts. As stated in the JAMA
patient papge (Appendix IV), the risks of ephedra far outweigh benefits.
Improved product safety testing, quality control, labeling, and nomenclature
are all needed in order to forestall or eliminate the problems now inherent with
the dietary supplement category of weight loss products.
Table 1. Patterns of Signs and Symptoms Associated
With Dietary Supplements Containing Ephedrine Alkaloids.
|
Organ/system
involved
|
Clinical
significance
|
Signs
and symptoms
|
|
Cardiovascular system
|
Serious
|
Dysrhythmias, severe hypertension, cardiac arrest,
angina, myocardial, infarction, and stroke
|
|
|
Less clinically significant
|
Tachycardia, mild hypertension, palpitations.
|
|
|
|
|
|
Nervous system
|
Serious.
|
Psychosis, suicidal, altered or loss of
consciousness (including disorientation or confusion), and seizures.
|
|
|
Less clinically significant
|
Anxiety, nervousness, tremor, hyperactivity,
insomnia, altered behavior, memory changes.
|
|
|
|
|
|
Gastrointestinal (GI)
|
Serious
|
Altered serum enzymes, hepatitis.
|
|
|
Less clinically significant
|
GI distress (nausea, vomiting, diarrhea,
constipation).
|
|
|
|
|
|
Dermatologic
|
Serious
|
Exfoliative dermatitis
|
|
|
Less clinically significant
|
Less clinically significantNonspecific rashes.
|
|
General manifestations
|
|
Numbness, tingling, dizziness, fatigue, lethargy,
weakness.
|
For the purposes of this
document, strokes (i.e., cerebrovascular accidents) are considered to be
related to
the
cardiovascular system, because predisposing or inciting factors include
hypertension, dysrhythmias and
References
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Treatments for Weight Loss: A Critical Review. Food Science and Nutrition. Food
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Heimburger D, Heymsfield SB, Lucas C, Robbins D, Chung J. Long-term weight
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3. Astrup A, Lundsgaard C, Madsen J, Christensen NJ. Enhanced thermogenic
responsiveness during chronic ephedrine treatment in man. Am J Clin Nutr
1985;42:83-94.
4. Astrup A, Madsen J, Holst J., and Christensen NJ. The Effect of Chronic
Ephedrine Treatment on Substrate Utilization, the Sympathoadrenal Activity, and
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Toubro, S. Pharmacological and clinical studies of ephedrine sand other
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a double-blind, multi-centre trial in general practice. International Journal of
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Dietary Supplements. Am J Health-Syst Pharm 2000;57:963-9.
14. Gurley BJ, Gardner SF, White LM, Wang P. Ephedrine pharmacokinetics after
the ingestion of nutritional supplements containing Ephedra sinica. Therapeut
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Pharmacokinetics and cardiovascular effects of MaHuang in normotensive adults. J
Clin Pharmacol 1997 37:116-22.
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Appendix I
Pharmacology of ephedra alkaloids and caffeine after
single-dose dietary supplement use.
Haller CA, Jacob P 3rd, Benowitz NL.
Division of Clinical Pharmacology, San Francisco General Hospital, University of
California, 94143, USA. dchaller@worldnet.att.net
OBJECTIVE: Serious cardiovascular toxicity has been reported in people taking
dietary supplements that contain ma huang (Ephedra) and guarana (caffeine). We
assessed the pharmacokinetics and pharmacodynamics of a dietary supplement that
contains these herbal stimulants. METHODS: Eight healthy adults received a
single oral dose of a thermogenic dietary supplement labeled to contain 20 mg
ephedrine alkaloids and 200 mg caffeine after an overnight fast. Serial plasma
and urine samples were analyzed by use of liquid chromatography-tandem mass
spectrometry for ephedrine alkaloid and caffeine concentrations, and heart rate
and blood pressure were monitored for 14 hours. RESULTS: Plasma clearance and
elimination half-lives for ephedrine, pseudoephedrine, and caffeine were
comparable to published values reported for drug formulations. A prolonged
half-life of ephedrine and pseudoephedrine was observed in 1 subject with the
highest urine pH. Mean systolic blood pressure increased significantly to a
maximum of 14 mm Hg above baseline at 90 minutes after ingestion (P <.001).
There was a lag in the mean heart rate response that reached a maximum change of
15 beats/min above baseline at 6 hours after ingestion (P <.001). Diastolic
blood pressure changes were insignificant. Two subjects who were taking oral
contraceptives had longer caffeine half-lives (15.5 +/- 0.3 hours versus 5.6 +/-
1.7 hours) and lower values for oral clearance (0.34 +/- 0.01 mL/min. kg versus
0.99 +/- 0.41 mL/min. kg) than subjects who were not taking oral contraceptives.
CONCLUSIONS: Botanical stimulants have disposition characteristics similar to
their pharmaceutical counterparts, and they can produce significant
cardiovascular responses after a single dose.
Appendix II

Appendix
III
(Click image for larger version)

Appendix IV (Click
image for larger version)

Appendix V
Adverse cardiovascular and
central nervous system events associated with dietary supplements containing
ephedra alkaloids.
Haller CA, Benowitz NL.
Department of Medicine, University of California, San Francisco, and the
California Poison Control System, 94143-1220, USA.
BACKGROUND: Dietary supplements that contain ephedra alkaloids (sometimes called
ma huang) are widely promoted and used in the United States as a means of losing
weight and increasing energy. In the light of recently reported adverse events
related to use of these products, the Food and Drug Administration (FDA) has
proposed limits on the dose and duration of use of such supplements. The FDA
requested an independent review of reports of adverse events related to the use
of supplements that contained ephedra alkaloids to assess causation and to
estimate the level of risk the use of these supplements poses to consumers.
METHODS: We reviewed 140 reports of adverse events related to the use of dietary
supplements containing ephedra alkaloids that were submitted to the FDA between
June 1, 1997, and March 31, 1999. A standardized rating system for assessing
causation was applied to each adverse event. RESULTS: Thirty-one percent of
cases were considered to be definitely or probably related to the use of
supplements containing ephedra alkaloids, and 31 percent were deemed to be
possibly related. Among the adverse events that were deemed definitely,
probably, or possibly related to the use of supplements containing ephedra
alkaloids, 47 percent involved cardiovascular symptoms and 18 percent involved
the central nervous system. Hypertension was the single most frequent adverse
effect (17 reports), followed by palpitations, tachycardia, or both (13); stroke
(10); and seizures (7). Ten events resulted in death, and 13 events produced
permanent disability, representing 26 percent of the definite, probable, and
possible cases. CONCLUSIONS: The use of dietary supplements that contain ephedra
alkaloids may pose a health risk to some persons. These findings indicate the
need for a better understanding of individual susceptibility to the adverse
effects of such dietary supplements.
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