In Reply We appreciate the letter written by Ciappio and McBurney as it brings the concept of varying nutrient intake recommendations between the Institute of Medicine (IOM) and the Food and Drug Administration (FDA) to the forefront. We contend that there are a few points that should be thought about when considering guidance from the FDA or IOM.
Owing to the current regulatory environment, dietary supplement manufacturers are not required to use neither the FDA guidance documents nor the IOM recommendations for absolute supplementation amount.1 Because the FDA nonbinding guidance for infants and children younger than 4 years is more than 2 decades old,2 we chose to compare dietary supplement labels with the latest IOM recommendations, as this is the most updated and comprehensive resource available. The FDA has issued a proposed rule stating, “We tentatively conclude that the existing reference daily intakes (RDIs) for vitamins and minerals should be revised based on the reference daily intakes set by the IOM that reflect the most current science regarding nutrient requirements.”3 Thus, we reaffirm our statement in light of the proposed rule that, based on our analysis, much of the pediatric vitamin supplementation is not based on IOM recommendations and therefore represents wholesale oversupplementation.4
Madden MM, DeBias D, Cook GE. Multiple Nutrient Intake Recommendations Guide Dietary Supplement Formulations—Reply. JAMA Pediatr. 2014;168(9):864-865. doi:10.1001/jamapediatrics.2014.429