By Randall E. White, author American Popular Sovereignty @2019
In an earlier blog we posted The Twelve Questions Letter an example of effective administrative letter-writing to public representatives for achieving political remedy. In this blog post we will consider another example of effective letter writing, which addresses the issue of requiring our representative government to include We the People in the process of determining what substances are Generally Recognized As Safe or “GRAS”, thus legally permitted to be made commercially available for public consumption without any undue government regulations interfering with or obstructing our access.
In the previous article, How to Write a Letter to Congressional Representatives and the President, we explained when raising an issue on the national level of government, the essential elements of effective letter-writing include:
- Writing to the five essential representative offices that are usually involved in making or enforcing public policy and laws, which are: (a) our President; (b) the chief executive officer in charge of the executive agency overseeing our issue; (c) our Representative in Congress; and (d) our two State Senators
- Explaining why the issue is of great national importance
- Citing the public authority under which We the People have a right to request representative action in the matter, together with our representatives’ duty to comply with our request
- Telling our representatives exactly what we want them to do: e.g., for the President to issue an Executive Order creating a certain public policy for the relevant executive agency to follow; and for our Representatives and Senators in Congress to support the public policy established in the Executive Order, together with creating or amending legislation which will solve the underlying problem that the Executive Order is temporarily fixing
- Sending the letter to our public representatives in the hundreds of thousands or millions to provide them with evidence of our public will in the matter, which they can use to leverage or defend political action on our behalf
The following is an example of an administrative letter wherein we are asking our President to issue an Executive Order requiring the FDA to make the only known safe and effective remedy for mercury toxicity available for public consumption. As stated in the earlier article, in the event that our public representatives do not comply with our administrative request, then our alternative remedy is to directly establish public policy or law through the ballot initiative process.
The “GRAS” Mercury Detox Letter
The letter template is in standard business letter format, as follows:
City, state, postal code
President Donald J. Trump; The White House; 1600 Pennsylvania Avenue NW; Washington, DC 20500
Commissioner Stephen Hahn; Food and Drug Administration; 10903 New Hampshire Ave.; Silver Spring, MD 20993-0002
Representative [name]; address; Washington, DC, postal code
Senator [name]; address; Washington, DC, postal code
Senator [name]; address; Washington, DC, postal code
Re: Declaring NBMI a/k/a Emeramide a/k/a Irminix as “GRAS”
Dear Public Representatives,
I am writing to you in my capacity as one of We the People, who are the creators of our government and having the authority to protect our public weal. This letter presents an issue of great national importance affecting millions of Americans who are suffering the harmful effects of mercury toxicity while the FDA is preventing us from accessing the only known safe and effective remedy.
What we are requesting is: (a) for our President to issue an Executive Order declaring the chemical compound NBMI a/k/a Emeramide a/k/a Irminix as Generally Recognized As Safe or “GRAS” for public consumption without needing a doctor’s prescription; (b) for the FDA to immediately comply by facilitating pharmaceutical distribution of NBMI / Emeramide / Irminix in America through over-the-counter sales and the Internet; and (c) for our Representatives and Senators in Congress to support the Executive Order and to create legislation requiring the FDA to include and facilitate We the People in the decision-making process of declaring which foods, food additives, food supplements, herbs and drugs qualify to receive the designation of “GRAS”. 
The United States Environmental Protection Agency (EPA) website states the following about mercury:
“Mercury is a neurotoxin. A neurotoxin is a substance that is known or suspected to be poisonous to nerve tissue. How someone’s health may be affected by an exposure to mercury depends on a number of factors:
- The form of mercury (for example, methylmercury or elemental (metallic) mercury);
- The amount of mercury in the exposure;
- The age of the person exposed (unborn infants are the most vulnerable);
- How long the exposure lasts;
- How the person is exposed — breathing, eating, skin contact, etc.; and
- The health of the person exposed.
The effects of mercury exposure can be very severe, subtle, or may not occur at all, depending on the factors above.” 
The chemical compound, N,N‘bis-(2-mercaptoethyl) isophthalamide (NBMI), could be widely beneficial to the millions of Americans suffering from mercury toxicity, if only this compound were to be properly declared GRAS and allowed to be sold over the counter and through the Internet to customers without a prescription. The holder of patent rights to marketing NBMI for oral consumption, EmeraMed Ltd, has been trying to bring NBMI to market as a drug after the FDA shut down marketing of NBMI as a health food supplement over ten years ago. EmeraMed has registered the names “Emeramide” and “Irminix” for the purpose of marketing NBMI as a drug. Their website describes Irminix as follows: 
“Irminix® is an exceptionally safe antidote for heavy metal poisoning and also a powerful antioxidant. It is currently going through the European Medical Agency (EMA) and the United States Food and Drug Administration (FDA) drug approval process.
Irminix® was first introduced to the dental/medical community in 2008 as an antioxidant supplement with adverse reporting tracked. It is made from two natural substances we eat every day. The first building block is carboxyl benzoate which is found naturally in cranberries. Carboxyl benzoate is widely used as a preservative in many foods and drinks and generally recognized as a safe compound. Two arms are made out of cysteamine (found naturally in meat and on the terminal end of Co-enzyme A) which is also a widely used natural antioxidant. The cysteamines have a sulfhydryl (-SH) at their terminal ends, and the amino ends are attached on the 1st and 3rd carbon groups of the carboxyl benzoate. This allows the -SH groups to flex, rotate and take many different positions to accommodate the binding parameters of several toxic metals that are attracted to -SH groups, which covers most toxic heavy metals.
About 2.5 million doses of the original Irminix® compound were sold as the supplement OSR#1® (Oxidative Stress Relief) with no significant adverse reactions reported to the listed adverse effects reporting site on the OSR containers nor to the FDA. There were, however, numerous anecdotal reports of remarkable recoveries that have guided the research required for drug development. Initial studies supported the safety of OSR#1® as a food supplement. Three clinical trials required for drug development have further established safety. The Phase 1 safety study and Phase 2 clinical trials showed no adverse effects in humans.” 
For these reasons, we thank you in advance for timely action on our behalf.
 White, R. (2019). Declare Our Right to Determine What Is “GRAS”. American Popular Sovereignty; A guide to restoring participatory government and achieving remedy. (pp. 198-201). Fort Worth, TX: APS Education.
 EPA. (2017, January 19). Health Effects of exposures to Mercury. Retrieved from https://www.epa.gov/mercury/health-effects-exposures-mercury#self
 EmeraMed. (2019). Irminix®: A safe metals chelator. Retrieved from https://emeramed.com/irminix-safe-metals-chelator/
 Schutzmeier, P.; Baquerizo, A. F.; Castillo-Tandazo, W.; Focil, N.; & Bose-O’Reilly, S. (2018, February 14). Efficacy of N,N‘bis-(2-mercaptoethyl) isophthalamide on mercury intoxication: a randomized controlled trial. Retrieved from https://ehjournal.biomedcentral.com/articles/10.1186/s12940-018-0358-1
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