I have been taking these supplements for almost three weeks now. What I have noticed is there is a marked difference in the decrease of my daily brain fog. This was huge for me! However, I gave the product 4 stars because of my concern about the high count of vitamin B6. I think this should have been addressed in a disclaimer for concerned consumers
Factor analysis. The strategy: read in the data, drop unnecessary data, impute missing variables (data is too heterogeneous and collected starting at varying intervals to be clean), estimate how many factors would fit best, factor analyze, pick the ones which look like they match best my ideas of what productive is, extract per-day estimates, and finally regress LLLT usage on the selected factors to look for increases.

Armodafinil is sort of a purified modafinil which Cephalon sells under the brand-name Nuvigil (and Sun under Waklert21). Armodafinil acts much the same way (see the ADS Drug Profile) but the modafinil variant filtered out are the faster-acting molecules22. Hence, it is supposed to last longer. as studies like Pharmacodynamic effects on alertness of single doses of armodafinil in healthy subjects during a nocturnal period of acute sleep loss seem to bear out; anecdotally, it’s also more powerful, with Cephalon offering pills with doses as low as 50mg. (To be technical, modafinil is racemic: it comes in two forms which are rotations, mirror-images of each other. The rotation usually doesn’t matter, but sometimes it matters tremendously - for example, one form of thalidomide stops morning sickness, and the other rotation causes hideous birth defects.)
When many of us think of memory enhancers, we think of ginkgo biloba, the herb that now generates more than $240 million in sales a year worldwide. The October 22-29, 1997 issue of the Journal of the American Medical Association reported that Alzheimer's patients who took 120 mg of ginkgo showed small improvements in tests designed to measure mental performance.
After we had ordered beers he said: "One of the most impressive features of being a student is how aware you are of a 24-hour work cycle. When you conceive of what you have to do for school, it's not in terms of nine to five but in terms of what you can physically do in a week while still achieving a variety of goals - social, romantic, extracurricular, CV-building, academic."
As you are no doubt well aware, coffee and cigarettes have long been a popular combination. Ah, nostalgia. Just think back to the 1950’s and the man in the suit perfectly pairing his black brew with a cigarette hanging out the corner of his mouth as he enjoyed the Sunday paper or rocked on a lazy afternoon out on the family patio. Heck, there’s even a movie called “Coffee and Cigarettes” and a song called “Cigarettes & Coffee” (in the former, you can see Bill Murray, Tom Waits, Steve Buscemi and Cate Blanchett partaking in their fair share of smoking and sipping).
(We already saw that too much iodine could poison both adults and children, and of course too little does not help much - iodine would seem to follow a U-curve like most supplements.) The listed doses at iherb.com often are ridiculously large: 10-50mg! These are doses that seems to actually be dangerous for long-term consumption, and I believe these are doses that are designed to completely suffocate the thyroid gland and prevent it from absorbing any more iodine - which is useful as a short-term radioactive fallout prophylactic, but quite useless from a supplementation standpoint. Fortunately, there are available doses at Fitzgerald 2012’s exact dose, which is roughly the daily RDA: 0.15mg. Even the contrarian materials seem to focus on a modest doubling or tripling of the existing RDA, so the range seems relatively narrow. I’m fairly confident I won’t overshoot if I go with 0.15-1mg, so let’s call this 90%.
He used to get his edge from Adderall, but after moving from New Jersey to San Francisco, he says, he couldn’t find a doctor who would write him a prescription. Driven to the Internet, he discovered a world of cognition-enhancing drugs known as nootropics — some prescription, some over-the-counter, others available on a worldwide gray market of private sellers — said to improve memory, attention, creativity and motivation.

Fortunately for me, the FDA decided Smart Powder’s advertising was too explicit and ordered its piracetam sales stopped; I was equivocal at the previous price point, but then I saw that between the bulk discount and the fire-sale coupon, 3kg was only $99.99 (shipping was amortized over that, the choline, caffeine, and tryptophan). So I ordered in September 2010. As well, I had decided to cap my own pills, eliminating the inconvenience and bad taste. 3kg goes a very long way so I am nowhere close to running out of my pills; there is nothing to report since, as the pills are simply part of my daily routine.
My answer is that this is not a lot of research or very good research (not nearly as good as the research on nicotine, eg.), and assuming it’s true, I don’t value long-term memory that much because LTM is something that is easily assisted or replaced (personal archives, and spaced repetition). For me, my problems tend to be more about akrasia and energy and not getting things done, so even if a stimulant comes with a little cost to long-term memory, it’s still useful for me. I’m going continue to use the caffeine. It’s not so bad in conjunction with tea, is very cheap, and I’m already addicted, so why not? Caffeine is extremely cheap, addictive, has minimal effects on health (and may be beneficial, from the various epidemiological associations with tea/coffee/chocolate & longevity), and costs extra to remove from drinks popular regardless of their caffeine content (coffee and tea again). What would be the point of carefully investigating it? Suppose there was conclusive evidence on the topic, the value of this evidence to me would be roughly $0 or since ignorance is bliss, negative money - because unless the negative effects were drastic (which current studies rule out, although tea has other issues like fluoride or metal contents), I would not change anything about my life. Why? I enjoy my tea too much. My usual tea seller doesn’t even have decaffeinated oolong in general, much less various varieties I might want to drink, apparently because de-caffeinating is so expensive it’s not worthwhile. What am I supposed to do, give up my tea and caffeine just to save on the cost of caffeine? Buy de-caffeinating machines (which I couldn’t even find any prices for, googling)? This also holds true for people who drink coffee or caffeinated soda. (As opposed to a drug like modafinil which is expensive, and so the value of a definitive answer is substantial and would justify some more extensive calculating of cost-benefit.)
He used to get his edge from Adderall, but after moving from New Jersey to San Francisco, he says, he couldn’t find a doctor who would write him a prescription. Driven to the Internet, he discovered a world of cognition-enhancing drugs known as nootropics — some prescription, some over-the-counter, others available on a worldwide gray market of private sellers — said to improve memory, attention, creativity and motivation.

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The bitter reality of life is that there’s no organ of our body, which can defy the effects of aging with success. At least not entirely on its own. That’s why we need supplements in the first place. Remember? That’s only the beginning of the bad news for your brain. Certain sections of our brain, especially prefrontal cortex and hippocampus, can be seriously reduced in size as you are getting older. In addition, the number of capillaries in your head reduces, as well. Let’s not forget the arteries that become narrower and therefore limit the blood flow.
Results: Women with high caffeine intakes had significantly higher rates of bone loss at the spine than did those with low intakes (−1.90 ± 0.97% compared with 1.19 ± 1.08%; P = 0.038). When the data were analyzed according to VDR genotype and caffeine intake, women with the tt genotype had significantly (P = 0.054) higher rates of bone loss at the spine (−8.14 ± 2.62%) than did women with the TT genotype (−0.34 ± 1.42%) when their caffeine intake was >300 mg/d…In 1994, Morrison et al (22) first reported an association between vitamin D receptor gene (VDR) polymorphism and BMD of the spine and hip in adults. After this initial report, the relation between VDR polymorphism and BMD, bone turnover, and bone loss has been extensively evaluated. The results of some studies support an association between VDR polymorphism and BMD (23-,25), whereas other studies showed no evidence for this association (26,27)…At baseline, no significant differences existed in serum parathyroid hormone, serum 25-hydroxyvitamin D, serum osteocalcin, and urinary N-telopeptide between the low- and high-caffeine groups (Table 1⇑). In the longitudinal study, the percentage of change in serum parathyroid hormone concentrations was significantly lower in the high-caffeine group than in the low-caffeine group (Table 2⇑). However, no significant differences existed in the percentage of change in serum 25-hydroxyvitamin D
The price is not as good as multivitamins or melatonin. The studies showing effects generally use pretty high dosages, 1-4g daily. I took 4 capsules a day for roughly 4g of omega acids. The jar of 400 is 100 days’ worth, and costs ~$17, or around 17¢ a day. The general health benefits push me over the edge of favoring its indefinite use, but looking to economize. Usually, small amounts of packaged substances are more expensive than bulk unprocessed, so I looked at fish oil fluid products; and unsurprisingly, liquid is more cost-effective than pills (but like with the powders, straight fish oil isn’t very appetizing) in lieu of membership somewhere or some other price-break. I bought 4 bottles (16 fluid ounces each) for $53.31 total (thanks to coupons & sales), and each bottle lasts around a month and a half for perhaps half a year, or ~$100 for a year’s supply. (As it turned out, the 4 bottles lasted from 4 December 2010 to 17 June 2011, or 195 days.) My next batch lasted 19 August 2011-20 February 2012, and cost $58.27. Since I needed to buy empty 00 capsules (for my lithium experiment) and a book (Stanovich 2010, for SIAI work) from Amazon, I bought 4 more bottles of 16fl oz Nature’s Answer (lemon-lime) at $48.44, which I began using 27 February 2012. So call it ~$70 a year.
Of course learning, working memory and cognitive control represent just a few aspects of thinking. Farah concluded that studies looking at other kinds of cognition - verbal fluency, for instance - were too few and too contradictory to tell us much. Both Chatterjee and Farah have wondered whether drugs that heighten users' focus might dampen their creativity. After all, some of our best ideas come to us not when we sit down at a desk but rather when we're in the shower or walking the dog - letting our minds roam. Jimi Hendrix reported that the inspiration for "Purple Haze" came to him in a dream; the chemist Friedrich August Kekule claimed that he discovered the ring structure of benzene during a reverie in which he saw the image of a snake biting its tail. Farah told me: "There is some evidence that suggests that individuals who are better able to focus on one thing and filter out distractions tend to be less creative.
Talk to your doctor, too, before diving in "to ensure that they do not conflict with current meds or cause a detrimental effect," Hohler says. You also want to consider what you already know about your health and body – if you have anxiety or are already sensitive to caffeine, for example, you may find that some of the supplements work a little too well and just enhance anxiety or make it difficult to sleep, Barbour says. Finances matter, too, of course: The retail price for Qualia Mind is $139 for 22 seven-capsule "servings"; the suggestion is to take one serving a day, five days a week. The retail price for Alpha Brain is $79.95 for 90 capsules; adults are advised to take two a day.
After we had ordered beers he said: "One of the most impressive features of being a student is how aware you are of a 24-hour work cycle. When you conceive of what you have to do for school, it's not in terms of nine to five but in terms of what you can physically do in a week while still achieving a variety of goals - social, romantic, extracurricular, CV-building, academic."
Taurine (Examine.com) was another gamble on my part, based mostly on its inclusion in energy drinks. I didn’t do as much research as I should have: it came as a shock to me when I read in Wikipedia that taurine has been shown to prevent oxidative stress induced by exercise and was an antioxidant - oxidative stress is a key part of how exercise creates health benefits and antioxidants inhibit those benefits.
The low-carb & high-fat diet (includes keto-diet) are not good for you because the brain needs glucose for fuel. It can burn fat. But, the brain’s preferred energy source is glucose. The key is to provide the brain with glucose without raising glucose/serum blood level. You do that by avoiding sugar and eating complex carbohydrates (fresh produce) that convert into glucose.
We did note a significant warning with this product, namely that the caffeine it contains may cause a negative impact, mainly that some users may experience the jitters. Their dosage suggests that one can take up to 6 pills a day, which we felt was too many. These issues made us a little wary of the product, even though they seem to know the right ingredients to include.
But he has also seen patients whose propensity for self-experimentation to improve cognition got out of hand. One chief executive he treated, Ngo said, developed an unhealthy predilection for albuterol, because he felt the asthma inhaler medicine kept him alert and productive long after others had quit working. Unfortunately, the drug ended up severely imbalancing his electrolytes, which can lead to dehydration, headaches, vision and cardiac problems, muscle contractions and, in extreme cases, seizures.

The greatly increased variance, but only somewhat increased mean, is consistent with nicotine operating on me with an inverted U-curve for dosage/performance (or the Yerkes-Dodson law): on good days, 1mg nicotine is too much and degrades performance (perhaps I am overstimulated and find it hard to focus on something as boring as n-back) while on bad days, nicotine is just right and improves n-back performance.

However, normally when you hear the term nootropic kicked around, people really mean a “cognitive enhancer” — something that does benefit thinking in some way (improved memory, faster speed-of-processing, increased concentration, or a combination of these, etc.), but might not meet the more rigorous definition above.  “Smart drugs” is another largely-interchangeable term.
Caffeine + L-Theanine: Since caffeine can produce unwanted side effects in high amounts (such as jitteriness and headaches), most people, and especially “slow caffeine oxidizers” find that by adding L-Theanine to a caffeine source such as coffee, any negative side effects of caffeine can be controlled. Caffeine and L-Theanine in combination have been researched and proven to boost concentration, attention, and energy while reducing anxiety. For this stack, use a ratio of four parts L-Theanine to one part caffeine, such as 400 milligrams of L-Theanine along with 100 milligrams of caffeine. You may want to start out with a smaller dose such as 200 milligrams of L-Theanine and 50 milligrams of caffeine and work your way up to find the best dose for you (the average cup of coffee has about 100mg of caffeine).
Any consideration of the future of nootropics is directly tied into the future of humanity. As long as work productivity demands continue to soar, there will like be a affiliated rise in the desire to increase brain power. As Vice discusses in a thoughtful article providing several insights into why nootropics are popular, it is not surprising that smart drugs and the nootropic industry are ever-expanding. Vice points out that sci-fi writers once warned of people being overtaken by machines, but instead, human beings are becoming machines, taking on unrealistic work levels.[15] Taking nootropic drugs is akin to loading up on premium fuel in an effort to go faster and do better.
The hormone testosterone (Examine.com; FDA adverse events) needs no introduction. This is one of the scariest substances I have considered using: it affects so many bodily systems in so many ways that it seems almost impossible to come up with a net summary, either positive or negative. With testosterone, the problem is not the usual nootropics problem that that there is a lack of human research, the problem is that the summary constitutes a textbook - or two. That said, the 2011 review The role of testosterone in social interaction (excerpts) gives me the impression that testosterone does indeed play into risk-taking, motivation, and social status-seeking; some useful links and a representative anecdote:
l-theanine (Examine.com) is occasionally mentioned on Reddit or Imminst or LessWrong33 but is rarely a top-level post or article; this is probably because theanine was discovered a very long time ago (>61 years ago), and it’s a pretty straightforward substance. It’s a weak relaxant/anxiolytic (Google Scholar) which is possibly responsible for a few of the health benefits of tea, and which works synergistically with caffeine (and is probably why caffeine delivered through coffee feels different from the same amount consumed in tea - in one study, separate caffeine and theanine were a mixed bag, but the combination beat placebo on all measurements). The half-life in humans seems to be pretty short, with van der Pijl 2010 putting it ~60 minutes. This suggests to me that regular tea consumption over a day is best, or at least that one should lower caffeine use - combining caffeine and theanine into a single-dose pill has the problem of caffeine’s half-life being much longer so the caffeine will be acting after the theanine has been largely eliminated. The problem with getting it via tea is that teas can vary widely in their theanine levels and the variations don’t seem to be consistent either, nor is it clear how to estimate them. (If you take a large dose in theanine like 400mg in water, you can taste the sweetness, but it’s subtle enough I doubt anyone can actually distinguish the theanine levels of tea; incidentally, r-theanine - the useless racemic other version - anecdotally tastes weaker and less sweet than l-theanine.)
Using neuroenhancers, Seltzer said, "is like customising yourself - customising your brain". For some people, he added, it was important to enhance their mood, so they took antidepressants; but for people like him it was more important "to increase mental horsepower". He said: "It's fundamentally a choice you're making about how you want to experience consciousness." Whereas the 1990s had been about "the personalisation of technology", this decade was about the personalisation of the brain - what some enthusiasts have begun to call "mind hacking".
Spinach is rich in the antioxidant lutein, which is thought to help protect against cognitive decline, according to researchers from Tufts University. And a longitudinal study at Harvard Medical School found that women who reported eating the most leafy green and cruciferous vegetables had a markedly lower rate of cognitive decline, compared to those who ate the least.

Cocoa flavanols (CF) positively influence physiological processes in ways which suggest that their consumption may improve aspects of cognitive function. This study investigated the acute cognitive and subjective effects of CF consumption during sustained mental demand. In this randomized, controlled, double-blinded, balanced, three period crossover trial 30 healthy adults consumed drinks containing 520 mg, 994 mg CF and a matched control, with a 3-day washout between drinks. Assessments included the state anxiety inventory and repeated 10-min cycles of a Cognitive Demand Battery comprising of two serial subtraction tasks (Serial Threes and Serial Sevens), a Rapid Visual Information Processing (RVIP) task and a mental fatigue scale, over the course of 1 h. Consumption of both 520 mg and 994 mg CF significantly improved Serial Threes performance. The 994 mg CF beverage significantly speeded RVIP responses but also resulted in more errors during Serial Sevens. Increases in self-reported mental fatigue were significantly attenuated by the consumption of the 520 mg CF beverage only. This is the first report of acute cognitive improvements following CF consumption in healthy adults. While the mechanisms underlying the effects are unknown they may be related to known effects of CF on endothelial function and blood flow.
Maybe you are you new to nootropics? The word, “Nootropic” is a very broad term describing a supplement or drug that increases mental performance. There are several different groups of nootropics including herbal supplements and a class of research chemicals known as racetams. Below are some of the many common benefits that may potentially be experienced with nootropic supplements.

Mosconi holds a dual PhD in neuroscience and nuclear medicine. She is the associate director of the Alzheimer’s Prevention Clinic at Weill Cornell Medical College/New York-Presbyterian Hospital, and the founder of the Nutrition and Brain Fitness Lab at New York University School of Medicine. With her training and experience, she ought to understand and practice rigorous science. She makes all the right noises about scientific literacy and recognizing pseudoscience, but she seems unable to look in the mirror and see her own errors.
My first time was relatively short: 10 minutes around the F3/F4 points, with another 5 minutes to the forehead. Awkward holding it up against one’s head, and I see why people talk of LED helmets, it’s boring waiting. No initial impressions except maybe feeling a bit mentally cloudy, but that goes away within 20 minutes of finishing when I took a nap outside in the sunlight. Lostfalco says Expectations: You will be tired after the first time for 2 to 24 hours. It’s perfectly normal., but I’m not sure - my dog woke me up very early and disturbed my sleep, so maybe that’s why I felt suddenly tired. On the second day, I escalated to 30 minutes on the forehead, and tried an hour on my finger joints. No particular observations except less tiredness than before and perhaps less joint ache. Third day: skipped forehead stimulation, exclusively knee & ankle. Fourth day: forehead at various spots for 30 minutes; tiredness 5/6/7/8th day (11/12/13/4): skipped. Ninth: forehead, 20 minutes. No noticeable effects.
[…] The 7 Best Brain Boosting Supplements | Live in the Now … – … much research has indicated that certain supplements can help sustain and promote excellent brain function as we age. The supplements recommended by the Alzheimer’s Prevention and … Take adequate supplements for brain and help your kids to perform well in their tests by enhancing … […]
As mentioned above, eating foods that are rich in indigestible fibre such as vegetables and fruits, as well as eating good fats that are found in grass-fed butter, nuts and seeds, olive oil, coconut oil and avocado, provide bacteria with prebiotics that help to produce the ‘friendly’ short-chain fatty acids such as butyrate. Avoiding processed foods that contain calcium propionate, which lead to higher levels of propionic acid - the not so friendly short-chain fatty acid - is also another key strategy to support the gut-brain link.
Alex's sense of who uses stimulants for so-called "non-medical" purposes is borne out by two dozen or so scientific studies. In 2005 a team led by Sean Esteban McCabe, a professor at the University of Michigan, reported that in the previous year 4.1% of American undergraduates had taken prescription stimulants for off-label use - at one school the figure was 25%, while a 2002 study at a small college found that more than 35% of the students had used prescription stimulants non-medically in the previous year.
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As discussed in my iodine essay (FDA adverse events), iodine is a powerful health intervention as it eliminates cretinism and improves average IQ by a shocking magnitude. If this effect were possible for non-fetuses in general, it would be the best nootropic ever discovered, and so I looked at it very closely. Unfortunately, after going through ~20 experiments looking for ones which intervened with iodine post-birth and took measures of cognitive function, my meta-analysis concludes that: the effect is small and driven mostly by one outlier study. Once you are born, it’s too late. But the results could be wrong, and iodine might be cheap enough to take anyway, or take for non-IQ reasons. (This possibility was further weakened for me by an August 2013 blood test of TSH which put me at 3.71 uIU/ml, comfortably within the reference range of 0.27-4.20.)


The single most reliable way to protect our brain cells as we age, most researchers agree, is to eat plenty of fruits and vegetables, which are chock-full of antioxidants and nutrients. In a study published in the October 1997 issue of the American Journal of Clinical Nutrition, researchers tested 260 people aged 65 to 90 with a series of mental exercises that involved memorizing words or doing mental arithmetic. The top performers were those who consumed the most fruits and vegetables and ate the least artery-clogging saturated fat.
Because modafinil works in a manner similar to methylphenidate, it also bears similar risks. The improper dosage or abuse of modafinil may lead to the disrupted development of executive controls like decision-making and working memory. Modafinil’s effects may also depend upon the IQ of the taker. Two university studies determined that in a test of sustained attention, modafinil only improved cognition in the group with “lower” IQs. Although safer than other stimulants due to its milder effect on neurotransmitter levels, there are still risks associated with any kind of drug that affects dopaminergic neurotransmission, mostly because this can lead to addiction and, similar to a pornography user who needs increasingly fringe porn to achieve the same effect, can produce a resistance or lowered sensitivity to dopamine.
Caffeine, Tulsi and Astragalus: Tulsi is one of the greatest calming adaptogens that exists, trusted and revered for centuries in Ayurvedic medicine and culture. Tulsi has been researched and shown to uplift mood, support digestion, and promote balanced energy. Because it’s also an anxiolytic (causes anti-anxiety effects) tulsi, similar to coffee with L-theanine, does a good job balancing out any over-stimulating effects of the caffeine in coffee. But you can also take things one step further and blend in astragalus, which, in Chinese medicine, is considered a “strong” Ki invigorating herb that provides a stable source of non-crashing energy. Astragalus also contains an enormous variety of saponins, flavonoids, and polysaccharides, and is considered to be a “longevity adaptogen”. Pairing with antioxidant-rich coffee and tulsi produces a match made in longevity heaven. For this blend, which I often use if drinking coffee in the afternoon, I’m a fan of the Four Sigmatic Adaptogen Blend, which contains coffee, astragalus, tulsi and cinnamon.
A large review published in 2011 found that the drug aids with the type of memory that allows us to explicitly remember past events (called long-term conscious memory), as opposed to the type that helps us remember how to do things like riding a bicycle without thinking about it (known as procedural or implicit memory.) The evidence is mixed on its effect on other types of executive function, such as planning or ability on fluency tests, which measure a person’s ability to generate sets of data—for example, words that begin with the same letter. 
"Instead of messing it up, we should be appreciating something that nature has taken years to optimize," Dr. Lisa mentions. But, we aren't messing it up voluntarily or, at the very least, on any conscious or malicious level. She attributes our disregard for neuro-nutrition to a series of factors, which include the portion size of meals, how parents don't have the time to cook or teach children how to eat healthily, the big influence of cafeteria food, and our "always on the go" culture. According to her, this leads us to unconsciously choose meals which are poor quality and high in sugars, a deathly combination for our brains.
Price discrimination is aided by barriers such as ignorance and oligopolies. An example of the former would be when I went to a Food Lion grocery store in search of spices, and noticed that there was a second selection of spices in the Hispanic/Latino ethnic food aisle, with unit prices perhaps a fourth of the regular McCormick-brand spices; I rather doubt that regular cinnamon varies that much in quality. An example of the latter would be using veterinary drugs on humans - any doctor to do so would probably be guilty of medical malpractice even if the drugs were manufactured in the same factories (as well they might be, considering economies of scale). Similarly, we can predict that whenever there is a veterinary drug which is chemically identical to a human drug, the veterinary drug will be much cheaper, regardless of actual manufacturing cost, than the human drug because pet owners do not value their pets more than themselves. Human drugs are ostensibly held to a higher standard than veterinary drugs; so if veterinary prices are higher, then there will be an arbitrage incentive to simply buy the cheaper human version and downgrade them to veterinary drugs.
Similar delicacies from around the world include Mexican tacos de sesos.[1] The Anyang tribe of Cameroon practiced a tradition in which a new tribal chief would consume the brain of a hunted gorilla, while another senior member of the tribe would eat the heart.[2] Indonesian cuisine specialty in Minangkabau cuisine also served beef brain in a coconut-milk gravy named gulai otak (beef brain curry).[3][4] In Cuban cuisine, "brain fritters" are made by coating pieces of brain with bread crumbs and then frying them.[5]
According to the US Food and Drug Administration, "Piracetam is not a vitamin, mineral, amino acid, herb or other botanical, or dietary substance for use by man to supplement the diet by increasing the total dietary intake. Further, piracetam is not a concentrate, metabolite, constituent, extract or combination of any such dietary ingredient. [...] Accordingly, these products are drugs, under section 201(g)(1)(C) of the Act, 21 U.S.C. § 321(g)(1)(C), because they are not foods and they are intended to affect the structure or any function of the body. Moreover, these products are new drugs as defined by section 201(p) of the Act, 21 U.S.C. § 321(p), because they are not generally recognized as safe and effective for use under the conditions prescribed, recommended, or suggested in their labeling."[33]
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