We sent a large stack of documentation to the FDA and the FTC refuting their claims that Comfrey is harmful. The following is a list of problems we saw in the studies that the FDA and FTC used to make their decision. Click on the numbers to find how we responded to them, or follow the links across the top.
1. Studies pointing to harmful effects of Symphytum officinale were performed with the root which has a higher Pyrrolizidine alkaloid content and is not used internally in Dr. Christopher formulas.
2. Studies were performed with extremely concentrated extracts or single constituents of the herb containing higher Pyrrolizidine alkaloid content than the whole plant.
3. Studies were performed by injecting plant constituents under the skin or in tissue cultures, exhibiting an unrealistic scenario of this plant's use.
4. Many studies cited in literature related to harmful effects of Symphytum officinale were performed on related species with higher Pyrrolizidine alkaloids content than Symphytum officinale.
5. Symphytum officinale has been shown to act as a cell proliferant and have analgesic effects in clinical studies.
6. Symphytum officinale has been clinically proven not to have carcinogenic effects.
7. Symphytum officinale contains hepatoprotective constituents that help protect the liver from damage, these substances are not included in tests of this plant and would effect the outcome of these tests.
8. Symphytum officinale has been used as a feed and forage crop for centuries without incident.
9. Symphytum officinale has demonstrated its safety through thousands of years of documented traditional use.
10. Symphytum officinale use has low incidence of hepatic problems.
11. Case studies that seem to show harmful effects from consuming Symphytum officinale reflect poor application of the scientific method.
12. Symphytum officinale has demonstrated its safety through 43 years of use in Dr. Christopher's formulas without incident.