Three Times Is Enemy Action

by David Archibald

9 October 2025

 

Actually, there’s four now: vitamin D, ivermectin, calcifediol and melatonin.

Vitamin D

The Therapeutic Good Administration (TGA) limits the content of vitamin D capsules made in Australia to 1,000 IU. For vitamin D, one IU is one fortieth of a millionth of a gram so 1,000 IU is 0.025 milligrams. Under natural conditions, UV light from the Sun makes 0.5 milligrams of vitamin D in the skin per day. East Africans living a traditional lifestyle have a blood vitamin D level of about 55 ng/ml. This is also what the average Australian level should be but we are less than half that at 25 ng/ml.

So, dictating that capsules made in Australia can’t be made with more than 1,000 IU of vitamin D means that, at one capsule per day, people are getting no more than 10% of what their skin should be producing. This would hardly make any difference. In the United States, capsules are made with up to 50,000 IU per capsule. A person’s vitamin D level makes a big difference to the sepsis rate after surgery so some surgeons are giving their patients bolus doses of beyond 200,000 IU followed by normal dosing. The Coimbra Protocol for treating multiple sclerosis uses a dose rate of 50,000 IU per day. It is very difficult to overdose on vitamin D.

Most of the world’s synthetic vitamin D is made in India by exposing lanolin to UVB. The price is about US$500/kg. A person taking 10,000 IU per day is consuming 91.2 milligrams per annum. At that rate, a gram of vitamin D will last 11 years at a cost of US$0.50 or nearly five US cents per annum at the wholesale level.

Vitamin D is the most cost-effective pharmaceutical on the planet. Doubling Australia’s average vitamin D level would halve our disease burden. But the TGA has made that difficult, unnecessarily difficult. Why would that be?

Ivermectin

Next up is ivermectin, highly effective in treating cancers, worms and viruses. Once again, it is as cheap as chips but the TGA has banned import of it.

Calcifediol

Calcifediol is formed in the liver from cholecalciferol, the form of vitamin D made in the skin and in vitamin D capsules. The liver takes about three days to process vitamin D into calcifediol, which is three times stronger than the parent molecule. So if you want the benefits of vitamin D fast, theoretically that would be possible by taking a sufficient dose of calcifediol. For example, on becoming aware that you have a covid infection, it is recommended to take 40,000 IU of calcifediol. The TGA has made that difficult by limiting the amount of calcifediol in capsules made in Australia to 400 IU which is ten millionths of a gram. To get the beneficial dose, you would have to drink a slurry of 100 capsules.

Melatonin

But the TGA’s recent decision on melatonin takes the prize for its nastiest and most egregious diktat. Melatonin is the most innocent and benign, yet quite beneficial, molecule in God’s creation. The oral dose that kills 50% (LD50) of rats has been determined to be 3,200 mg/kg of body weight. To get to a human equivalent dose, divide the rat result by six which comes to 533 mg/kg. A 90% safety margin would take the likely safe dosing limit to 53 mg/kg. Nevetheless, a good daily limit for melatonin consumption is likely to be around 60 mg/day.

The pineal gland’s production of melatonin is regulated by visible blue light at about 480 nm, at up to 0.3 mg per day with the blood level peaking around 3.00 am. The body also produces as much as 600 mg of melatonin per day in mitochondria due to infrared light at around 820 nm. This melatonin is consumed in the mitochondria that produced it. This may explain the paradox that outdoor workers have a higher incidence of skin cancers but a lower death rate from melanomas.

The TGA’s diktat made melatonin prescription only, for a maximum of 30 capsules of 2 mg each per pack. Retail pricing is now $1 per milligram in Australia, equating to $1,000 per gram or $1 million per kg. This is more than five times the current gold price. The wholesale price for melatonin out of India is currently around US$500 per kg. The more than 1,300 fold markup from wholesale to retail in Australia explains the TGA’s enthusiasm for making melatonin prescription-only in tiny amounts.

By comparison, in the US it is possible to buy a bottle of 240 tablets of 5 mg each for US$7.99. This equates to A$0.01 per milligram, one hundredth the Australian price.

It seems the United States doesn’t have people overdosing on melatonin, they are able to cope with what they have bought.

Another rule for covid vaccines

India is open slather on pharmaceuticals but Indians don’t have a reputation for overdosing themselves. Are Australians any less capable of handling our drugs than Indians? Not that the TGA cares about the health of Australians; they approved the covid vaccines without bothering to read the documentation on the trials.

The TGA is running amok and curse them, but the root of the problem is the succession of federal health ministers who have let the TGA run the industry for the benefit of the pharma companies and themselves. The simplest solution would be to make any drug that is available in India legal for sale in Australia.

 

David Archibald is the author of The Anticancer Garden in Australia.