What the Institute of Medicine SHOULD have said

The news is full of comments, along with many attention-grabbing headlines, about the announcement from the Institute of Medicine that the new Recommended Daily Allowance (RDA) for vitamin D should be 600 units per day for adults.

What surprised me was the certainty with which some of the more outspoken committee members expressed with their view that 1) the desirable serum 25-hydroxy vitamin D level was only 20 ng/ml, and 2) that most Americans already obtain a sufficient quantity of vitamin D.

Here's what I believe the Institute of Medicine SHOULD have said:

Multiple lines of evidence suggest that there is a plausible biological basis for vitamin D's effects on cancer, inflammatory responses, bone health, and metabolic responses including insulin responsiveness and blood glucose. However, the full extent and magnitude of these responses has not yet been fully characterized.

Given the substantial observations reported in several large epidemiologic studies that show an inverse correlation between 25-hydroxy vitamin D levels and mortality, there is without question an association between vitamin D and mortality from cancer, cardiovascular disease, and all cause mortality. However, it has not been established that there are cause-effect relationships, as this cannot be established by epidemiologic study.

While the adverse health effects of 25-hydroxy vitamin D levels of less than 30 ng/ml have been established, the evidence supporting achieving higher 25-hydroxy vitamin D levels remains insufficient, limited to epidemiologic observations on cancer incidence. However, should 25-hydroxy vitamin D levels of greater than 30 ng/ml be shown to be desirable for ideal health, then vitamin D deficiency has potential to be the most widespread deficiency of the modern age.

Given the potential for vitamin D's impact on multiple facets of health, as suggested by preliminary epidemiologic and basic science data, we suggest that future research efforts be focused on establishing 1) the ideal level of 25-hydroxy vitamin D levels to achieve cancer-preventing, bone health-preserving or reversing, and cardiovascular health preventive benefits, 2) the racial and genetic (vitamin D receptor, VDR) variants that may account for varying effects in different populations, 3) whether vitamin D restoration has potential to exert not just health-preserving effects, but also treatment effects, specifically as adjunct to conventional cancer and osteoporosis therapies, and 4) how such vitamin D restoration is best achieved.

Until the above crucial issues are clarified, we advise Americans that vitamin D is a necessary and important nutrient for multiple facets of health but, given current evidence, are unable to specify a level of vitamin D intake that is likely to be safe, effective, and fully beneficial for all Americans.

Instead of a careful, science-minded conclusion that meets the painfully conservative demands of crafting broad public policy, the committee instead chose to dogmatically pull the discussion back to the 1990s, ignoring the flood of compelling evidence that suggests that vitamin D is among the most important public health issues of the age.

Believe it or not, this new, though anemic, RDA represents progress: It's a (small) step farther down the road towards broader recognition and acceptance that higher intakes (or skin exposures) to achieve higher vitamin D levels are good for health.

My view: Vitamin D remains among the most substantial, life-changing health issues of our age. Having restored 25-hydroxy vitamin D levels in over 1000 people, I have no doubt whatsoever that vitamin D achieves substantial benefits in health with virtually no downside, provided 25-hydroxy vitamin D levels are monitored.

Comments (47) -

  • Peter

    12/1/2010 2:27:18 AM |

    The headlines could have sais IOM raises RDA of Vitamin D 50%.

  • Jenny

    12/1/2010 2:29:45 AM |

    There is as yet NO study where supplementation with Vitamin D was shwon to reverse or improve any of the conditions with which the deficiency is associated.

    We can't call for evidence based medicine and then dismiss that call when the evidence isn't there to support our pet theories.

    I have not found any studies suggesting that Vitamin D improves blood sugar control in people who had low levels, and though I get an avalanche of mail from the diabetes community I have not heard from anyone whose blood sugar improved after taking it.

    So my conclusion is that it is not the cure all that some people would like it to be. With the unhappy history of Vitamin A, C, and E supplementation (which turn out to be ineffective or in the case of the antioxidants correlate with higher mortality) the people making these kinds of recommendations are right to be cautious.

    And given the very bad outcome with the megadose injections, and the poor quality of the expensive supplements, it's probably good they didn't endorse it more enthusiastically. More study is needed, particularly in regard to setting doses so people don't end up with milk alkali syndrome.

  • Anonymous

    12/1/2010 5:01:18 AM |

    I'm somewhat convinced I've experienced many health benefits from D supplementation.  I'm also somewhat convinced it's played a significant role in my body's new habit of making kidney stones.

  • PY

    12/1/2010 11:10:26 AM |

    Isn't the burden of proof on vitamin D proponents to show supplementation has a unambiguously positive effect, particularly when there is concern that there may be negative effects?  Your response here unfortunately doesn't give us much to stand on as vitamin D users, in terms of any rigorous data-based conclusions (as opposed to observational conclusions).  That is somewhat concerning.

  • PY

    12/1/2010 11:14:37 AM |

    Here is one article on the ISM panel's conclusions.  I am re-posting it here, as it my previous comment with the link was deleted from the previous post on this blog:


    From the article:

    "But Andrew Shao, an executive vice president at the Council for Responsible Nutrition, a trade group, said the panel was being overly cautious, especially in its recommendations about vitamin D.  He said there was no convincing evidence that people were being harmed by taking supplements, and he said higher levels of vitamin D, in particular, could be beneficial.

    Such claims “are not supported by the available evidence,” the committee wrote. They were based on studies that observed populations and concluded that people with lower levels of the vitamin had more of various diseases. Such studies have been misleading and most scientists agree that they cannot determine cause and effect.

    It is not clear how or why the claims for high vitamin D levels started, medical experts say. First there were two studies, which turned out to be incorrect, that said people needed 30 nanograms of vitamin D per milliliter of blood, the upper end of what the committee says is a normal range. They were followed by articles and claims and books saying much higher levels — 40 to 50 nanograms or even higher — were needed.

    After reviewing the data, the committee concluded that the evidence for the benefits of high levels of vitamin D was “inconsistent and/or conflicting and did not demonstrate causality.”

    Evidence also suggests that high levels of vitamin D can increase the risks for fractures and the overall death rate and can raise the risk for other diseases. While those studies are not conclusive, any risk looms large when there is no demonstrable benefit. Those hints of risk are “challenging the concept that ‘more is better,’ ” the committee wrote.

    That is what surprised Dr. Black. “We thought that probably higher is better,” he said.

    He has changed his mind, and expects others will too: “I think this report will make people more cautious.”

  • Jim

    12/1/2010 11:46:18 AM |

    Just wanted to say that I really appreciate what Dr. Davis brings to this site.  

    And I also appreciate the community here that is not afraid to push back from time to time with thoughtful opposing comments.  

    After what we have seen in the last 30 years, at this point, it should take a lot of convincing any time vitamin x or food y is offered up as the next great health wonder.

  • qualia

    12/1/2010 2:33:20 PM |

    @jenny i really can't take your comments seriously. you doesn't seem to know what you're talking about at all.

    "poor quality of the expensive supplements"

    SERIOUSLY?? vitamin D3 is one of the cheapest and simplest supplement you can get on the market. a years supply of 5000IU even from high-quality, reputable brands rarely costs more than 15-20$ on-line. wtf are you talking about?

  • Anonymous

    12/1/2010 2:52:38 PM |

    Jenny's right, when I take anything above 1500 IU/day (conservative according to more and more proponents of D3 supplementation) I get sign of hypercalcaemia immediately.

    And yes, I have tried adding K2, makes no difference.

    I'm from Northern European heritage and suspect that we need very little D.

  • Nigel Kinbrum

    12/1/2010 3:15:48 PM |

    Anonymous said...
    "Jenny's right, when I take anything above 1500 IU/day (conservative according to more and more proponents of D3 supplementation) I get sign of hypercalcaemia immediately.

    And yes, I have tried adding K2, makes no difference.

    I'm from Northern European heritage and suspect that we need very little D."

    I'm descended from Poles & Lithuanians and have normal serum Calcium (by blood test) on 5,000iu/day D3. Have you been tested for Sarcoidosis, Primary Hyperparathyroidism, Milk-alkali Syndrome or any other medical condition that can result in hypercalcaemia?

    K2 doesn't prevent hypercalcaemia. It only reduces inappropriate calcification that can occur even with normocalcaemia.

  • Anand Srivastava

    12/1/2010 3:40:54 PM |

    When taking supplements that should not cause problems normally, and you experience problems there is normally an underlying problem.

    My brother was detected Hashimoto's when supplementing iodine.

    My wife has a single kidney, and very high doses of vitamin D causes her problem. But 4000IU is not a problem.

    If you are getting a problem at 1500IU, you should get yourself tested for hyperparathyroidism. It is a pretty common result of Vitamin D supplementation. There may be other reasons why Vitmain D3 may cause problems, particularly in renal system.

    It is good to take these vitamin once in a higher dose to determine if you have any problem related to their dosage.

  • Anne

    12/1/2010 7:11:10 PM |

    Jenny - Here's a study: 'Vitamin D and diabetes Improvement of glycemic control with vitamin D3 repletion':


  • Anonymous

    12/1/2010 11:00:35 PM |

    Anyone here ever read "The Real Truth About Vitamins and Antioxidants" by Judith DeCava ?

    Most "vitamins" are actually very high doses of only parts or fractions of naturally occuring vitamins. Therefore they act like drugs, not like nutrition. They CANNOT help organs heal.
    Dr. Gus

  • Anonymous

    12/1/2010 11:47:41 PM |

    I weigh 114 lbs and take 2400 IU daily (softgels). I recently tested at 56 after 2 years of supplementation. Although, last summer I took 5000 IU daily. I am concerned about excess D, but I don't have a doctor. I won't be stabbing my fingers again since my finger still hasn't recovered from a home test. It still hurts after 6 weeks. I believe vitamin D has helped me, and I don't really want to cut back on the dose. However, I'm reducing the dose to an average of 2000 IU daily. I will try to test with Life Extension next time if I can find a lab around here - definitely vein jab only! I wish I had a good doctor.

  • Anonymous

    12/2/2010 12:42:37 AM |

    Well I guess most of the time we Canadians are in lock-stock with our neighbors on the continent


    that is a big improvement though.  The 4000IU max is half what I take but then again, this is a recommendation for a healthy individual not someone with a family history of heart disease like me.

    K2 max is about a quarter of my daily:-

    But apparently for fish oil I am on target:-

    I tell people about this site every chance I get

  • Peter

    12/2/2010 1:09:20 AM |

    There is one study referred to in The Perfect Health Diet (which parallels the advice in this blog very closely) that people who had blood levels of Vitamin D over 80 had triple the heart disease.  This from southern India.

  • Anonymous

    12/2/2010 1:51:33 AM |

    and what do you expect from a self styled government organization?
    At least people with any sort of common sense and knowledge will know to disregard their "advice". And there is really no difference between 20 or 30 or 50 to 60. The gene transcription only starts after 100, I know I am supplementing vitamin D up to a million units per day to deal with various issues and I must say it works. I feel that vitamin D in such doses has a real effect on athletic abilities, I am sprinting like a teenager again and many other health improvements. Bottom line Dr. Davis, don't lose your time and nerves with the noise from governments and various "experts" , that's just barking up a wrong tree. They have an agenda to rule over us and it's only a matter of whether we allow them or not.

  • Dr. William Davis

    12/2/2010 2:06:33 AM |

    I put as much stock in the Institute of Medicine's advice on vitamin D, or any other vitamin for that matter, as I do the advice of the USDA on nutrition. Both have declared themselves irrelevant by their almost ridiculous detachment from reality.

    The data are overwhelming: Vitamin D is intimately associated with multiple facets of health.

    Another issue: The committee appears to be applying a drug-like standard to vitamin D: They require placebo vs. treatment clinical trials, a standard that other vitamins have not been held up to.

  • Anonymous

    12/2/2010 2:07:28 AM |

    Goodness!  All of this focus on "science."  There really should be focus on just getting enough of this nutrient on a regular basis without interference from sunshine phobia and the lack of good nutrition from fats.

  • Dr. William Davis

    12/2/2010 2:09:40 AM |

    Sorry, Jenny, but I believe that you are flat wrong.

    While the studies tend to be small, there are indeed studies that have shown reversal of various conditions, including reversal of blood markers for bone resorption, insulin resistance, c-reactive protein, hyperparathyroidism, hypercalcemia, etc.

    Just because vitamin D has not enjoyed the deep-pocketed budget of a drug company's backing and therefore does not yet have a vitamin D vs placebo trial does not mean that humans do not need it or don't need more of it.

    I am personally appalled at the committee's closed-mindedness at what I believe is an incredibly important "supplement." Frankly, I don't care what the IOM says; I continue to do what I believe is right and what has worked for me and my patients time and time again.

  • Garry

    12/2/2010 2:24:11 AM |

    Dr. Davis,
    Do you routinely monitor blood calcium levels in your vitamin D-supplemented patients?  Thanks.

  • Daniel A. Clinton, RN, BSN

    12/2/2010 6:25:05 AM |

    This new recommendation accomplishes absolutely nothing. Those who are still ignorant as to the absurd irrelevance of consensus opinions by government health offices or medical professional organizations will continue to be Vitamin D deficient. And those of us who are really good at interpreting data and have thoroughly researched Vitamin D will trust our read of the data over all the propaganda.  All this does is show that we are at least 15 years ahead of most everyone else, and that's actually really sad, and something I refuse to accept because America deserves better.

  • Patricia D.

    12/2/2010 8:54:15 AM |

    Regarding the above mentioned statement by Dr. Cannell of the Vitamin D Council: Today, the FNB has failed millions... - Toward the end, Dr. Cannell discusses his intention to have the suppressed reports - by Vitamin D experts associated with the decision by the FNB - made public.  Which would be great.

  • Anonymous

    12/2/2010 9:49:15 AM |

    Hey, if they go on "progressing" that way the RDA will be quite allright in...em... 250 years...
    Let's celebrate!

  • Drs. Cynthia and David

    12/2/2010 10:34:11 AM |

    Many of the studies that have been done have used very small doses of vit D, so the failure to show unequivocal results is not surprising.  The associational studies don't prove causation of course but certainly provide hypotheses for testing.  So the conservative approach (CYA) is to recommend low doses still.  A search of clinicaltrials.gov for vit D trials shows a ton of trials being initiated.  We will have to wait a few years for the results to be reported and interpreted.  Meanwhile, I supplement with 5000 units per day but don't take calcium as that doesn't seem to be necessary with adequate D levels, and my calcium level is right where it should be.  


  • Adam

    12/2/2010 1:01:32 PM |

    I'm tempted to write a faux press release from the IOM saying that there is little conclusive evidence that Vitamin C is related to scurvy and that we should be cautious in making radical arguments for fruit in the navy. ;)

  • Steve Cooksey

    12/2/2010 1:36:37 PM |

    I agree with Dr. Davis on D3.

    Primarily due to my own experience. I supplement with Vit D3 (4-6k) and Omega 3 Daily.

    I am a type 2 diabetic who has normal blood sugar AND I take -0- drugs and -0- insulin.

  • Peter

    12/2/2010 1:50:27 PM |

    One study that would be very cheap and fast would be to test Dr.Davis's observation that vitamin D from tablets doesn't reliably raise blood levels like gelcaps do.

  • Anonymous

    12/2/2010 7:26:26 PM |

    The Vitamin D issue is becoming the Global Warming controversy of the medical world. I haven't seen such sharp divisions in the medical community over the efficacy of any other drug/supplement as this one. The usual way this goes is that for any non-pharmaceutical/non-prescription item, there always strong push back from the governing medical bodies, despite empirical data suggesting benefit.

  • DK

    12/3/2010 2:32:46 AM |

    I have no doubt whatsoever that vitamin D achieves substantial benefits in health with virtually no downside, provided 25-hydroxy vitamin D levels are monitored.

    Don't you think such statements are a tad cavalier? Literature certainly does not give one such level of confidence. There are several indicators that some cancers increase with increasing Vit. D. Plus, there are bound to be ethnic and gender differences in response to vit. D. And you have no doubt that treating everyone the same to achieve the same and largely random number is a good thing? Wow, just wow.

  • Anonymous

    12/3/2010 8:27:18 PM |

    This seems scary, Vitamin D associated with increased risk of pancreatic cancer:


  • Travis Culp

    12/3/2010 9:00:55 PM |

    Just wait until there is a Lovaza-like pharmaceutical D3 that costs 1000 dollars a month and suddenly the RDA will rise to where it should be.

  • Anonymous

    12/3/2010 11:01:48 PM |


      I have seen HbA1c improve in couple of cases with Vitamin D supplementation. Here's a reference to a similar observation http://timesofindia.indiatimes.com/home/science/Lack-of-vitamin-D-poses-diabetes-risk/articleshow/6922336.cms

    -- DK

  • Anonymous

    12/7/2010 4:58:12 PM |

    Make sure to avoid vitamin A supplements (including cod liver oil), unless you're truly deficient. Excess vitamin A blocks vitamin D benefits. I read this on the vitamin D council site.

  • Anonymous

    12/8/2010 12:07:23 AM |

    Relevant articles:

    "Anticancer Vitamins du Jour—The ABCED's So Far"


    "Vitamin D in Cancer Patients: Above All, Do No Harm"

  • O Primitivo

    12/8/2010 12:18:29 AM |

    There are only 8 trials on vitamin D and Diabetes, and some of them are null - http://www.ncbi.nlm.nih.gov/pubmed?term=vitamin%20d[title]%20AND%20diabetes[title]%20AND%20%28Clinical%20Trial[ptyp]%20OR%20Randomized%20Controlled%20Trial[ptyp]%29

  • Nigel Kinbrum

    12/8/2010 2:04:04 PM |

    RE Null Trials:-
    In Avenell et al, only 800iu/day was used.
    In de Boer et al, only 400iu/day was used.
    In Orwoll et al, calcitriol 1ug/day for only 4 days was used.

  • O Primitivo

    12/8/2010 5:45:35 PM |

    Nigel, thanks for the correction. I truly believe vitamin D supplementaion and more exposure is beneficial. The full IOM ob-line report is available here - http://www.nap.edu/catalog.php?record_id=13050

  • O Primitivo

    12/8/2010 5:59:12 PM |

    The "desirable" levels this institute assumed are not based on evolutionary evidence, they only considered the minimum level to avoid rickets. Here is a free 29-page pdf summary of the report: http://www.nap.edu/nap-cgi/report.cgi?record_id=13050&type=pdfxsum

  • Dana Seilhan

    12/11/2010 9:07:51 AM |

    I don't know what Jenny means by studies done on vitamin A.  They did a study on beta carotene and smokers.  I have my own pet hypothesis about that:  there's some thinking that cancers eat so much glucose not only because it's the only fuel many of the cancer types can use, but because it protects them from oxidation.  It makes me wonder if beta carotene encouraged lung cancer in that smokers study because the cancer cells were vulnerable to oxidative damage and the BC protected them!

    Be that as it may, beta carotene is not vitamin A, any more than clay is a brick.

    I cured a three-year run of excessive menstruation by supplementing retinol from fish liver oil.  Anecdotal evidence, I know, but the more I dig around on Science Daily and similar websites, the more I find connections between vitamin A and reproductive health, including sound development of the embryo and fetus.  I don't know where researchers get the notion that vitamin A causes birth defects;  it may actually do the exact opposite.

    I have heard criticisms that where researchers have made claims about the harmfulness of vitamin A, they are doing so based on data about synthetic vitamin A.  Fish liver oil--and hey, land-animal liver if you like to eat it--shouldn't be a problem then.

    And anyone who intakes the fat-soluble vitamins all out of balance is going to have a problem.  I'd recommend reading the Weston A. Price Foundation's information on the subject.  For instance, the ratio of vitamin A to vitamin D intake in the diet should be at least 10 to 1 or better (9 to 1, 8 to 1, etc.).

    There is still so much we don't know about these vitamins.  But in healthy populations with low dental caries and birth defect rates and with ideal or near-ideal development of facial bone structure, the intake of fat-solubles was several times the American intake in the early 1900s, when it was still considerably higher than it is in the U.S. today!  They had lab tests back then for all the fat-solubles except K, which was discovered later.  So this was documented.

    More recent studies have shown that calcium is not as well absorbed in a diet that is too high in fiber relative to fat intake.  WAPF claims that fat-soluble vitamins are necessary for the assimilation of minerals;  we've seen that with vitamin D and calcium and (if I'm not mistaken) vitamin A and iron.  There are definite connections between FS vitamins and health, even if no one's handed stone tablets down from heaven to show us either way.  There is evidence.  You just have to want to see it.

  • Kathy Kaufman's blog

    12/11/2010 12:27:17 PM |

    Dr. Davis, I had an interesting anecdotal experience from taking vitamin D.  I have suffered from canker sores since I was a young child. I'm in my sixties now and they seem to be getting worse and more frequent with multiple outbreaks to the point sometimes it was hard to speak.  Recently my MD tested my vitamin D levels and said they were too high (100) and I should cut back. I cut back and 2 days later I got 3 canker sores.  I hadn't even realized I didn't have one in the 8 months I'd been taking vitamin D.  I know the experts need to see all the clinical studies. The rest of us just want to be healthy! ( Prevention Magazine said broccoli could protect against cancer in the 1960s. Its taken the experts 50 years to catch up. )

  • Anonymous

    12/15/2010 11:13:52 AM |

    In light of the fact that the body can synthesis 10,000 IU of D3 in a short time exposed to UVB (AKA, Sunlight)...With no adverse effects, I dont understand how supplementing with say 5000IU daily, is a bad thing.

    These paltry, overly conservative recommendations are coming from  organization(s) who have got a whole lot of things wrong in the past regarding diet etc. And for the most part still are.

    Its funny that we live in a society that has a complete meltdown about supplementation issues, but doesn't generate the same hysteria or debate about the amount of diet soda, cheetos, processed foods in general, that are consumed. Funny time we are living in.

  • Garry

    12/17/2010 11:25:48 PM |

    Along the lines of Dana's comment, here's an interesting blog article by Chris Masterjohn on the topic of D, A and K.

  • George

    2/2/2011 10:42:55 PM |

    Dr Davis, I have had good lipid results, overall health with a lowercarb, nonprocessed food, no wheat diet and vitamin D suppplementation over the last 3 years. Unfortunately, have also discovered the agony of calcium oxalate kidney stones (3 episodes/3 years). Have seen some studies implicating higher protein diets and vitamin d supplementation. Have you run into kidney stones with any of your patients on vitamin d supplemention?

  • Dave

    5/12/2011 7:14:31 PM |

    To whom it may concern.  I began supplementing with Vitamin D3 a few years ago.  Right at first, I was having a considerable amount of restless legs and restless sleep.  There were other side effects that included increased muscular spasms.  Upon further research, I started supplementing with extra Magnesium. ( I was already taking MagOx which obviously was not getting absorbed).  The magnesium was a highly absorbable magnesium malate. (Magnesium glycinate is good too).  Anyway, after a few weeks the side effects disappeared and I have not had those problems since.  Vitamin D3 increases calcium absorption.  We must have an increase of magnesium to balance calcium.  Just a little FYI for those of you having kidney stones or other side effects from your vitamin D3 supplementation.