David vs Goliath Revisited

David and Goliath story is a fascinating story of overcoming obstacles. Here is a video I have been watching while I was waiting for the response from EFSA (European Food Safety Agency) and the EU commission, which explains my reference to David and Goliath. The essence of the story and the reason for David’s victory was no mystery; he had a superior weapon. My superior weapon in this specific battle with EFSA and the EU commission was the most powerful weapon ever devised; TRUTH.

Truth, however, is not self evident. It must be used with great courage and a true heart. The truth is once you have truth on your side courage follows without effort. It looks like courage from someone looking from the outside. Embracing truth has a consequence – once you embrace truth, courage then embraces you. The following story gives my personal example and the video explains it with mathematical precision by Malcolm Gladwell

I have been fighting against the bureaucratic Goliath for the last 6 years in Greece and the EU over how to implement the EU 432/2012 health claim for polyphenols in olive oil.

Today, Feb 20 2018, I was victorious. Not just for myself because this victory was not achieved for my own benefit. It is victory of science over superstition and deceit. It is a victory dedicated to the hundreds and thousands of olive growers who work and toil every day to maintain their olive groves and produce some of the most excellent olive oils in the world but are still forced to sell them off to greedy traders for a price that does not even cover their costs let alone their labor, let alone acknowledge their superior qualities for health.

They trusted me and they trusted the scientists like Dr.Prokopios Magiatis and Dr Eleni Melliou. They were successful in producing high phenolic olive oil but could not bring it to market because of the obstacles being placed in front of them by the special interests from the olive oil industry who did not want the status quo to change.

Checking out the olive oil selection

Victory over the bureaucrats who insisted the olive oil be measured by an inaccurate method that under reported the actual phenolic content, supported by politicians, that looked the other way, certain olive oil tasting “experts”, misguided “scientists”. Growers were threatened with fines and seizures if they did not comply. Some of them succumbed and others gave up and others went bankrupt. Others hung on inspired by my own rhetoric and others succeeded by donating their olive oil for medical research instead of selling it to the traders in bulk, and other succeeded by gambling last savings to bring their high phenolic olive oil to market.

I hurt, I cried and I celebrated with you every step of the way. I have also spent all my life savings on this grand vision – to revive the ancient “medicinal” quality of early harvest high phenolic olive oil. It is part of our Hellenic heritage and I see it being revived.

“we have begun the grand journey of reclaiming ancient wisdom using modern science”

I am happy to report we have finally succeeded!

I finally received official confirmation IOC (international Olive Council) approved method (HPLC) should NOT be used to measure phenolic content in olive oil in regards to the EU 432/2012 health claim for polyphenols in olive oil.

There are very few scientists I respect but 2 scientists stand out for their courage and intelligence on this issue; Dr. Prokopios Magiatis and Dr Eleni Melliou of the University of Athens.

Since 2012 they have also faced and suffered the slings and arrows hurled against them from lesser minds and hearts and stayed the course. They are my inspiration. They should be exalted instead of being vilified by the same bureaucrats and others who I went up against.

The links in the paragraph below are the email exchanges I had with EFSA and the EUropean commission.

final battle, however, was a lonely affair during the worst time of my life financially and health-wise. With a death sentence hanging over my head – I had nothing to lose. I followed the thread of truth without wavering and came out of the labyrinth. The bureaucratic Minotaur is defeated and it’s time to get back to producing the finest health promoting, health protective and what may soon be recognized as natural medicine – high phenolic olive oil.

This is the best olive oil made from early harvest green olives from specific varieties that are plentiful in Greece and Cyprus. It is no coincidence the first ever health claim for food was created by the ancient Hellenic culture:

“Let Food be thy medicine and let medicine be thy food” Hippocrates

We faced a daunting task of attempting to unravel the Gordian Knot and the fierce opposition that was created to stall or dismiss the EU 432/2012 health claim of polyphenols in olive oil. This confusion was fed by certain Greek olive oil industry insiders dedicated to selling off our best early harvest olive oils at bulk prices to foreign producers, the National Food Agency in Greece (EFET) and the others in the EU, certain well known scientists and olive oil experts, certain organoleptic experts who did not want objective scientific criteria of phenolic content to be a major criteria of deciding which is truly the best olive oil, the IOC (International Olive Council) who did not want an accurate method of measuring the concentration of polyphenols, and a host of politicians and bureaucrats here in Greece and abroad who looked the other way despite their claims to the opposite.

https://www.oliveoiltimes.com/olive-oil-basics/new-tool-evaluates-olive-oil-healthfulness/30480

EFET (National Greek Food Safety Agency) created one obstacle after another. Despite being given the same info I gave to EFSA and the European Commission they refused to listen to reason and insisted the IOC approved method (HPLC) was the only one to be used for confirmation of the phenolic content in EVOO in order to be allowed to place the health claim on the label. HPLC under measures phenolic content by about 50%. It is capable of only measuring phenolic concentrations up to 800mg per kg and is wildly inaccurate. EFET even staged scientific committees to study the matter and then falsely claimed the scientific decision was that HPLC should be used.

Here was my first clue on how to slay the Goliath. It was given to me unwittingly by someone who seems to be opposed to olive oil even having a health claim:

432/2012 health claim

At SEVITEL seminar they continue to debate on how to measure polyphenols in olive oil

It began to unravel last June 23 2018 when I attended a seminar at SEVITEL (the Greek Olive Oil Bottlers Association) where they were going to discuss polyphenols and the EU 432/2012 health claim. I saw the participants were the scientists that were adamant the only valid method to use is the “IOC approved” HPLC. So, I decided to pay the price (€100) and attend to listen to scientists practice what looked like to me the art of deception instead of science. At one point I told Despoina Tsipi the head of the Greek National Laboratory, that I have an email from Dr Maria Isabel Covas who oversaw the clinical trials that created the basis for the health claim. She informed me the method used was not the IOC (HPLC) method it was the LC-MS/MS method. Despoina Tsipi head of the National Greek Laboratory told me “EFSA says differently. HPLC is the method that was used for the EU health claim and not LC-MS/MS” I then asked her: “where does it say that? Show me.” She turned her back and walked away.

https://aristoleo.com/how-do-you-measure-phenolic-content-in-evoo/

All the scientists present seemed to agree with her point of view. Here are their names: Leonidas Palilis and Andreas Papioannou  representing EFET, Leandros Skaltsounis from the Univerity of Athens, Dr Stella Iosifidou representing the National Greek Laboratory. They insisted the IOC method was the only validated method. Dismissing the well-known fact the health claim did not use an officially validated method to separate and measure phenolic compounds. It is also known by all the scientists present HPLC does not measure phenolic concentrations accurately based on their individual molecular weight.

https://aristoleo.com/evoo-labeling-in-disarray/

So, I decided to take her word for it and wrote to EFSA to ask them if this is true. They responded by sending me the EFSA Scientific opinion on the substantiation of health claims and pointed to a section that falsely stated that HPLC was used for the measurement of phenolic compounds for the health claim.

Here is their opinion:

“In a multicentre (six centres in Finland, Denmark, Germany, Italy and Spain), randomised, cross-over, controlled human intervention study, olive oils with high (366 mg/kg olive oil, i.e. 8.0 mg/day; hydroxytyrosol content 63.5 mg/L, tyrosol 24.4 mg/L, and oleuropein derivatives 327.2 mg/L as measured by HPLC) moderate (164 mg/kg olive oil, i.e. 3.6 mg/day, hydroxytyrosol content approx. 28.5 mg/L), and low (2.7 mg/kg olive oil, i.e. 0.1 mg/day, no hydroxytyrosol) phenolic content were consumed (25 mL/day) by 200 male subjects for three weeks (Covas et al., 2006b). The phenolic composition and content of the olive oils used in this study are reported by de la Torre-Carbot et al. (2010).

Light bulb lit up over my head and I could finally see daylight. Here is my reply: “the sling” of undeniable truth that defeated the bureaucratic Goliath:

from: Athan Gadanidis <Aristoleo.com@gmail.com>
to: EFSA Press <Press.Press@efsa.europa.eu>,
BRAY Edward <Edward.BRAY@efsa.europa.eu>,
anca.paduraru@ec.europa.eu,
agogonaki@efet.gr,
Samona Aspasia <asamona@efet.gr>,
news@notismarias.gr

Dear all,

I have written several times over the last year. This is the final attempt before this goes to the court of justice and the European Parliament.

Here it is in black and white. EFSA scientific opinion contradicts their own advice to the National Food Safety Agencies of the EU. EFSA is falsely claiming that HPLC was the method used for compliance for EU 432/2012 health claim labeling regulation.

EFSA is bound by their own charter to use scientific evidence to back up their opinions. In this case they have not done so.

EFSA has willfully misinterpreted the scientific basis for this health claim and has consequently caused great financial loses to the MED region olive growers over the last 7 years of needless time consuming debate, misinformation and accrued losses by the olive growers for whom this health claim was supposed to help.

The olive growers have been threatened with fines and seizures of their olive oils if they do not comply with the HPLC method of measurement. Since the HPLC method was not used for establishing the minimum required polyphenols it cannot be used for compliance. This is especially egregious because HPLC under measures the phenolic content by at least 50% as compared with the method that was used in the Eurolive study HPLC MS/MS that established the minimum requirement of polyphenols that must be present in the olive oil to place the health claim of the label. 5mg per 20gm of olive oil.

Several olive grower groups, associations and co-ops are considering lawsuits so I suggest you act quickly to rectify your error and prepare to pay damages for your negligence. I suggest next time you hire people with no hidden agendas… because this is too flagrant of an error to be an “honest” mistake

Act accordingly.
Best regards Athan Gadanidis +35797645011 (Cyprus) +306947287828 (Greece)

EFSA scientific opinion (see attached)

Page 10 3rd paragraph In a multicentre (six centres in Finland, Denmark, Germany, Italy and Spain), randomised, cross-over, controlled human intervention study, olive oils with high (366 mg/kg olive oil, i.e. 8.0 mg/day; hydroxytyrosol content 63.5 mg/L, tyrosol 24.4 mg/L, and oleuropein derivatives 327.2 mg/L as measured by HPLC) moderate (164 mg/kg olive oil, i.e. 3.6 mg/day, hydroxytyrosol content approx. 28.5 mg/L), and low (2.7 mg/kg olive oil, i.e. 0.1 mg/day, no hydroxytyrosol) phenolic content were consumed (25 mL/day) by 200 male subjects for three weeks (Covas et al., 2006b). The phenolic composition and content of the olive oils used in this study are reported by de la Torre-Carbot et al. (2010).

Your own reference below contradicts your statement suggesting as measured by HPLC (see above)

de la Torre-Carbot et al. (2010). (see attached) Page 2 in the PDF version

Materials and Methods Olive oil characteristics and analysis. The oils used were specially prepared for the study. The total phenol concentration of the oils was measured by HPLC-diode array detection (DAD) (Hewlett-Packard- 1050 with an automatic injector and DAD 1050 series instrument) and HPLC-tandem MS (HPLC-MS/MS) (Agilent 1100) equipped with an autosampler and coupled to an API3000 triple-quadrupole mass spectrometer (PE Sciex) (48).

  1. De La Torre-Carbot K, Jauregui O, Gimeno E, Castellote AI, Lamuela-Raventos RM, Lopez-Sabater MC. Characterization and quantification of phenolic compounds in olive oils by solid-phase extraction, HPLC DAD, and HPLC-MS/MS. J Agric Food Chem. 2005;53:4331–40.

Here is the latest response from EFSA and the European Commission

Dear Athan,

We’ve had several exchanges over the last months. I appreciate the considerable research you have carried out into this topic and recognise the concerns you raise on behalf of olive growers. I take your concerns very seriously and I hope this e-mail will clarify in detail the points you have made.

Firstly, I stress that in its scientific opinions related to health claims EFSA is never prescriptive on the detection methods that may be used for the purposes of a health claim.

When the EFSA opinion you refer to indicates the measurement was done by ‘HPLC method’, it does refer to the methodology provided to substantiate the claim at the time of the submission of the dossier.  Use of the term ‘HPLC method’ does not exclude the specific detection methods that are related such as ‘HPLC-MS/MS’ or ‘HPLC-DAD’ in this case.

It is known that HPLC is a chromatographic principle that separates compounds according to polarity – but for detection HPLC needs to be combined with for example with MS, MS/MS, UV, diode array.

Detailed information of the specific methods used for characterisation of the content of olive oil polyphenols can be found in the study by de la Torre-Carbot et al. (2010), quoted in EFSA’s opinion, which indicates “HPLC-diode array detection (DAD) […] and HPLC-tandem MS (HPLC-MS/MS) […]”. Using the methods described in the references afore-mentioned (also quoted in the EFSA opinion) for characterisation of the content of olive oil polyphenols should therefore be considered acceptable. It is the responsibility of the national authorities, the Greek authorities in this instance, for implementing the conditions of use and for controls on the claim. EFSA has informed the European Commission, who to our understanding, has clarified the issue with the Greek authorities in recent days. I would suggest you to follow up with the Greek authorities.

I hope this clarifies. Kind regards, Edward Bray.

Here is my latest response… it’s not over until its over…

Dear Edward,
Thank you for finally confirming the obvious. But I must still kindly ask for clarification on one point that you made. In the Scientific opinion it does not say “HPLC method” it says HPLC. Your statement that it is written as “HPLC method” does not seem to be true. Please show me where in the scientific opinion of EFSA it says as you state HPLC method. It certainly was not in the section you directed me to read. I searched the whole document and there is not even one reference to “HPLC method”.

“In a multicentre (six centres in Finland, Denmark, Germany, Italy and Spain), randomised, cross-over, controlled human intervention study, olive oils with high (366 mg/kg olive oil, i.e. 8.0 mg/day; hydroxytyrosol content 63.5 mg/L, tyrosol 24.4 mg/L, and oleuropein derivatives 327.2 mg/L as measured by HPLC) moderate (164 mg/kg olive oil, i.e. 3.6 mg/day, hydroxytyrosol content approx. 28.5 mg/L), and low (2.7 mg/kg olive oil, i.e. 0.1 mg/day, no hydroxytyrosol) phenolic content were consumed (25 mL/day) by 200 male subjects for three weeks (Covas et al., 2006b). The phenolic composition and content of the olive oils used in this study are reported by de la Torre-Carbot et al. (2010).

Thanking you in advance for your consideration, I know this is very tedious but it’s nothing when compared to the silly, tedious and semantically incorrect arguments that I have heard over the last 7 years from well known scientists.

I would expect that you would immediately issue a press release to ensure the proper and thorough dissemination of this clarification regarding how to measure phenolic concentration in order to implement EU 432/2012 health claim for polyphenols in olive oil.

I believe we have wasted enough time with semantics instead of focusing on the upliftment of the olive growing regions this health claim was designed to support.

Now more than ever we must focus on supporting independent farmers to return to their olive groves. This can only happen if there are clear and set rules instead of semantic loopholes of one type or another.

Thank you for your attention to this matter over the last 7 months we have been in conversation I really appreciate it.

All the best
Athan Gadanidis

EFSA scientific opinion (see attached) Page 10 3rd paragraph

Scientific opinion-2011-EFSA_Journal

de la Torre-Carbot et al. (2010). (see attached) Page 2 in the PDF version

de la Torre-Carbot. J Nutr 2010