We often examine the claims made by companies or individuals for their health products, especially those we feel are making dubious claims based on questionable science. In 2012 Harriet Hall wrote an excellent review of one multi-level marketing company, ASEA, who are basically selling salt water with a load of dubious pseudoscientific claims. ASEA is just about a perfect example of everything we try to warn consumers about when it comes to dubious supplements and the inadequacies of current regulations.
When we post such reviews it is not uncommon for the company to give us push back, and it is much more likely if that company sells through multi-level marketing (). We recently received an e-mail from the “ASEA Team” who were not happy about Harriet’s review. They asked us to revisit our review (be careful what you wish for), concluding:
Bottom Line for our part:
The criticism of ASEA made by Mr. Hall [sic] is not constructive and Author’s points of view are not based on decent and verifiable facts. On the contrary, we have provided you with reliable information that is proven by the documentation. So, the article is misleading and deceives your website’s auditory and our potential and current customers. We are sure that after a deep consideration you will come to a conclusion and agree with us that it would be best to delete the article. Thank you.
After deep consideration, and re-review of the ASEA current website, I have come to the personal conclusion (and hope they will agree) that ASEA is selling quackery and nonsense with misleading claims designed to defraud both their customers and their sales agents (who often overlap). I suspect there is a combination of (financially) motivated reasoning and scientific illiteracy on their part, so I will explain again why I have come to this conclusion.
Let’s take their points in the ASEA team e-mail to SBM. They begin by objecting to Harriet’s (who they refer to as male throughout their letter) listing of the claims they were making on their website at the time:
- Promotes enhanced immune function
- Supports the vital activity of cellular communication
- Provides superior “support” to athletes
- Boosts efficiency of the body’s own antioxidants by 500%
- Protects against free radical damage
This information is out of date and does not correspond to reality, you can not even find these statements up on our website anymore. We have changed the formula, carefully tested it out and conducted several studies that proved that ASEA products have been shown to signal the activation of genetic pathways or affect genes that:
Improve immune system health;
Help maintain a healthy inflammatory response;
Help maintain cardiovascular health and support arterial elasticity;
Improve gut health and digestive enzyme production;
Modulate hormone balance to support vitality and wellness.
I see, they swapped out one list of dubious claims for a slightly tweaked list of dubious claims. “Promotes enhanced immune function” became “Improve immune system health.” And of course if you go to their website the old claims are still there, maybe not in the same location and jot list, but deeper in the copy or the linked “studies.” They are still claiming it improves cell signaling and increasing the body’s own anti-oxidants.
As a side point, we do not maintain and update every article. That is not standard or practical, nor is it expected, nor do we claim to. Articles are clearly dated, and it should be obvious they are only as current as the date they were posted. We will make corrections if they are pointed out to us or we discover them, and we use our own discretion in deciding whether or not to write an addendum or an updated article.
Their next point was so clueless it gave me the impression that we were dealing with low-level sales people who are not only scientifically illiterate, but had no backing from anyone with legal experience. In response to Harriet pointing out that ASEA is not making disease claims, because they can’t, they responded:
This statement doesn’t make any sense. As it was correctly noticed, we can’t legally and we actually don’t claim that ASEA is effective for any disease, so there is no point in writing more about this and even mentioning this. There is no information up on our website that says that ASEA would cure cancer or other diseases, however we do say that ASEA improves immune system health as well as has some other beneficial effects for a human being, and as we pinpointed that before, the effects have been verified by several laboratory tests. This statement made by Mr. Hall is far-fetched and offensive and shows that the Author tends to make things up and base his article on assumptions rather than on the facts.
Where do I begin? Here is the very salient point that Harriet was making, and that we make frequently on SBM. The current US regulations allow companies to make “structure-function” claims for their “supplements” without FDA oversight. Products with disease claims are, by definition, drugs and subject to FDA regulation. So what do many supplement companies do? They make structure-function claims that sound as if they may be beneficial for health, and combine those legally allowed claims with other statements about diseases, hoping their potential customers will connect the dots. They are skirting the spirit of the law in order to imply, without directly making, unsupported health claims.
On ASEA’s website they make the following claims:
- Decline of cell signaling causes cellular breakdown, which in turn causes a long list of common diseases including autoimmune and cardiovascular disease.
- ASEA improves cell-signaling which decreases cellular breakdown.
- Here is some (not peer-reviewed) science showing that ASEA alters markers which we will choose to interpret as “improving” some aspect of cell signaling or function.
So they do not directly say that ASEA cures any disease, because they know that it is not legal under current regulation, but they do imply that it does through the above chain of claims. That is standard procedure in the dubious corners of the supplement industry (i.e. most of the supplement industry).
Let’s get to the scientific studies they use to support their claims. In response to Harriet’s review they wrote:
The studies that Mr. Hall is referring to are old and no longer available on the ASEA website. Instead, we have conducted other studies that proved the effect of the ASEA products as well as their safety.
So, were those previous studies not valid? Science is cumulative. We don’t just scrub “old” studies from the record and replace them with new studies. In my opinion that reveals the marketing mentality of the “ASEA team”. Studies are not used to determine if their product works, but to support their marketing claims that it does work.
As Harriet pointed out, their studies are not being performed by academic scientists and published in peer-reviewed journals. They are being outsourced to third party research companies for hire. There is no paper-trail of research that would lead an honest scientist to the conclusions that ASEA is now selling. They appear to have started with their product and are backfilling in essentially worthless studies (as far as clinical claims go) to support their marketing.
Perhaps the biggest problem with ASEA’s “research” is that they don’t actually address their implied clinical claims. In other words – there are no studies that directly show that ASEA will improve your health – let alone multiple independently replicated rigorous studies published in peer-reviewed journals.
Their current marketing focuses heavily on the claim that ASEA increases natural antioxidants in the body. Antioxidants are currently very popular, having been given a health halo by two decades of heavy marketing. However, the real science tells a different story. In their scientific summary they write:
Oxidative damage has been implicated in aging and agedependent diseases, including cardiovascular disease, cancer, neurodegenerative disorders, and other chronic conditions. If the generation of free radicals exceeds the protective effects of antioxidants and some co-factors, this can cause oxidative damage.
That is the simplistic story that the anti-oxidant industry is selling, but it is nonsense. Essentially they are assuming that increasing antioxidant activity (even assuming that ASEA does so, which I doubt) must be a good thing. This turns out to be a naive assumption. A homeostatic balance between oxygen free radicals and antioxidants evolved to optimality, unless adversely affected by a disease state such as a genetic mutation. There is no reason to think that artificially disrupting this natural homeostasis would be a good thing. In fact, the evidence has shown that actual antioxidants taken in large amounts are bad for your health. Our bodies use free radicals as part of the immune system, to kill invading cells, and as important signaling molecules. Blocking free radicals in a healthy person can actual cause harm.
The same is true of immune function, which naturally exists in a carefully-balanced state. ASEA marketing naively assumes that increasing any arbitrary marker of immune function equals “improving” immune function. If you have an auto-immune disease, increasing immune function would be a bad thing.
This is the core fallacy of the entire supplement industry, which assumes that you can “improve” the function of an evolved homeostatic system by simply pushing it in one direction. This often leads to contradictory claims, such as some supplements claiming to increase oxygen while others claim to be anti-oxidants.
Finally, Harriet appropriately asked what was in ASEA anyway. It appears to be just salt and water, and ASEA makes the pseudoscientific claim that the salt water molecules have been arranged somehow into these redox signaling molecules. They respond:
As for what the components are, this is a confidential information. We have spent a lot of time and resources coming up with the idea as well as setting it all in motion.
Sorry, but science requires transparency. You cannot pretend to be scientific and then simultaneously state that your core claim is a secret. This is especially true when that core claim makes no scientific sense. It is not an extrapolation of existing scientific research or established principles. In fact, their core claim sounds like utter nonsense, so simply saying that it is a secret does not inspire confidence.
Far from taking down Harriet’s original review of ASEA and their claims, her assessment deserves to be updated and amplified. ASEAs marketing practices, in my opinion, are clearly deceptive. They use a lot of pseudoscientific claims representing the epitome of supplement industry misdirection and obfuscation. They use science as a marketing tool, not as a method for legitimately advancing our knowledge or answering questions about the efficacy of specific interventions.
I am amused that they chose to e-mail us with their juvenile analysis and requests. That may suggest they are more naïve than calculating, but it really doesn’t matter. They are selling a product with health claims. They have the responsibility not to deceive their customers, and I do not feel as if they have met their burden for due diligence. They may have from a regulatory perspective, but only because current regulations are horrifically inadequate. But they certainly haven’t from a moral or scientific perspective.